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Environmental Audit Report,

740-742 Toorak Road,

Hawthorn East, Victoria

(CARMS#47449-2)

February 2009

Leighton Properties

Parsons Brinckerhoff Australia Pty Limited ABN 80 078 004 798

Level 7, 457 St Kilda Road Melbourne VIC 3004 PO Box 7209 Melbourne VIC 8004 Australia

Telephone +61 3 9861 1111 Facsimile +61 3 9861 1144 Email [email protected]

ABN 80 078 004 798 NCSI Certified Quality System ISO 9001

Parsons Brinckerhoff supports the Environment

by printing on 100% recycled paper

2125047A 001 RPT 001 B0 CSI dc (M06347)

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© Parsons Brinckerhoff Australia Pty Limited (PB) [2008]. Copyright in the drawings, information and data recorded in this document (the information) is the property of PB. This document and the information are solely for the use of the authorised recipient and this document may not be used, copied or reproduced in whole or part for any purpose other than that for which it was supplied by PB. PB makes no representation, undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document or the information.

Author: John Throssell

Signed:

Approved by: John Throssell

Signed:

Date: 23 February 2009

Distribution: 1 x EPA, 1 x Leighton Properties, 1 x PB library, 1 x File copy

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Contents

Page Number ENVIRONMENT PROTECTION ACT 1970 STATEMENT OF ENVIRONMENTAL AUDIT ...... iii

Executive summary ...... vi

1. Introduction ...... 1 1.1 Purpose 1 2. Site details ...... 2 2.1 Description 2 2.2 History 2 2.3 Planning considerations 3 2.4 Geology and hydrogeology 4 2.4.1 Geology 4 2.4.2 Hydrogeology 4 2.4.3 Surface water 6 3. Beneficial uses ...... 7 3.1 Land 7 3.1.1 Soil assessment criteria 7 3.2 Groundwater 9 3.2.1 Groundwater assessment criteria 9 3.3 Surface water 12 3.3.1 Surface water assessment criteria 12 3.4 Consideration of beneficial uses 13 4. Investigation and remedial works ...... 14 4.1 Soil investigations 14 4.2 Soil remediation 17 4.3 Management of excavated materials/stockpiles 17 4.4 Groundwater investigations 17 4.5 Surface water investigations 23 4.6 Final condition of the site 24 5. Quality of available data ...... 26 5.1 Review of environmental site assessment data 26 5.2 Site history review 27 5.3 Soil investigations 28 5.4 Groundwater investigations 35 5.5 Surface Water Investigations 49 5.6 Auditor observations of field protocols 50 6. Discussion ...... 51 6.1 Beneficial uses of land 51 6.2 Beneficial uses of groundwater 52 6.3 Groundwater quality restricted use zone 53 7. Conclusions ...... 54

8. References ...... 57

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Contents (continued) Page Number

List of tables Table 2-1: Site geology 4 Table 2-2: Site hydrogeology 5 Table 3-1 Protected beneficial uses of land 7 Table 3-2: Soil assessment criteria 8 Table 3-3: Groundwater protected beneficial uses 9 Table 3-4: Groundwater and surface water investigation levels in micrograms per litre (µg/L)* 10 Table 4-1: Summary of previous site soil investigation works 15 Table 4-2: Summary of previous site groundwater investigation works 18 Table 4-3: Summary of groundwater results exceeding beneficial use criteria (May 2008) 20 Table 4-4: Site locations exceeding NEPM F criteria 24 Table 5-1: Quality of site history reviews 27 Table 5-2: Quality of soil investigation works 28 Table 5-3: Quality of groundwater investigation works 36 Table 5-4: Quality of surface water investigation works 49 Table 6-1: Assessment of impacts to beneficial uses of land 51 Table 6-2: Assessment of impacts to relevant groundwater beneficial uses 52

List of figures Figure 1: Site Locality Plan Figure 2: Site Layout Plan Figure 3: Groundwater Elevation Contours, May 2008 Figure 4: Extent of site excavations Figure 5: Location of Residual Soil Impacts Requiring Ongoing Management Figure 6: Groundwater Impact Plan, Free Cyanide and Benzene, May 2008 GME Figure 7: Site Plan May 2008 Figure 8: Plan of GQRUZ

List of appendices

Appendix A Figures Appendix B Tabulated Laboratory Results (Groundwater and Surface Water) from Bureau Veritas June 2008 Report Appendix C Certificate of Title Appendix D Correspondence Appendix E CUTEP Report Appendix F Information Supplied to Assist in the Understanding of an Environment Audit Report (Contaminated Land) Appendix G Assessor Reports Appendix H Groundwater Quality Management Plan & Reference Document

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Parsons Level 15 Brinckerhoff 28 Freshwater Place Australia SOUTHBANK VIC 3006 Pty Limited PO Box 19016 SOUTHBANK VIC 3006 ABN 80 078 004 798 Australia Telephone +61 3 9861 1111 Facsimile +61 3 9861 1144 Email [email protected]

Certified to ISO 9001; ISO 14001; AS/NZS 4801 1 September 2010

ADDENDUM TO STATEMENT OF ENVIRONMENTAL AUDIT

740-742 Toorak Road, Hawthorn East, Victoria (CARMS # 47449-2)

Background The Statement of Environmental Audit for the property located at 740-742 Toorak Road is subject to the following conditions (among others) relating to groundwater:

The Groundwater Quality Management Plan 742 Toorak Road, Hawthorn East (Bureau Veritas, 2009) prepared for the site and approved by EPA is to be implemented.

The Statement of Environmental Audit also includes a provision for the review of the implementation of the Groundwater Quality Management Plan i.e.

By September 2009, complete an environmental audit under Section 53V of the Act to re-assess the risk of harm to Gardiners Creek caused by the discharge of polluted groundwater from the site.

An Environmental Audit Report in relation to the risk of harm to the environment (Gardiners Creek) in accordance with Section 53V of the Environmental Protection Act, 1970, was completed in December 2009 (Parsons Brinckerhoff 2009) and included the following recommendations:

Groundwater abstraction wells should be decommissioned in accordance with abandonment requirements specified by Southern Rural Water.

No further monitoring of Gardiners Creek is required to be undertaken.

No future intervention based on groundwater quality is considered necessary in relation to the risk of harm to Gardiners Creek. Intervention should only be based on the periodic reassessment of risk to users of the underground car park.

The existing Groundwater Quality Management Plan for the site must be updated to reflect these recommendations.

The EPA has reviewed the Environmental Audit Report dated 22 December 2009 and found the recommendations to be acceptable. As a result the EPA requested that the Statement of Environmental Audit dated 23 February 2009 be amended to reflect the implementation and change in requirements of the Groundwater Management Plan.

Accordingly, the Auditor makes the following amendments to the Statement of Environmental Audit dated 23 February 2009:

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GROUNDWATER QUALITY MANAGEMENT PLAN

740 - 742 TOORAK ROAD

HAWTHORN EAST

VIC

Prepared on behalf of: Leighton Properties Pty Limited

Report No: 717022-R1.6

Revision 6

August 2010

Prepared by: Kenneth Nogeire

Reviewed by: ...... Page 9 of 87

1. INTRODUCTION

Since February 2002, Bureau Veritas HSE Pty Ltd (Bureau Veritas) [formerly Kilpatrick and Associates Pty Ltd] have been undertaking Environmental Site Assessment (ESA) works at the property located at 742 Toorak Road, Hawthorn East (Site). These works were initially performed on behalf of Australand - Apartments Division and later for Leighton Properties Pty Limited.

The Site is currently vacant and occupies a surface area of approximately 2.83 hectares. Historically, a gas storage facility comprising three gas holders was located in the western portion of the Site. The gas holders have been decommissioned. Two have been backfilled and one has been converted to an underground car park.

It is understood that groundwater contamination on Site is resultant from the storage and distribution of manufactured gas. Gas manufacturing waste was potentially used on Site as filling material.

Groundwater monitored on Site is characterised by elevated concentrations of benzene and cyanide. A combination of select metals and additional organic contaminants have also been reported at elevated concentrations (refer to Table 1 for a range of concentrations of contaminants of concern (COC) reported in 2008 and 2009).

A review of select monitored natural attenuation parameters suggests that subsurface conditions are amenable to the biodegradation of COCs within the groundwater environment.

The Victorian EPA has identified the Site to be located within a Groundwater Quality Restricted Use Zone (GRUZ), defined as the site, the land between the site and Gardiners Creek, and the land between the site and the northern boundary of Toorak Road (refer to attached Figure 1: Site Plan).

This Groundwater Quality Management Plan (GQMP) forms part of the Addendum to Statement of Environmental Audit, 740-742 Toorak Road, Hawthorn East, Victoria (CARMS # 47449-4) dated - August 2010.

This document is also to be read in conjunction with the following documents:

Parsons Brinckerhoff (2009). Environmental Audit Report 740 – 742 Toorak Road Hawthorn East Victoria - CARMS #47449/39717 (PB Site Audit Report)

Parsons Brinckerhoff (2009) document titled Environmental Audit Report, 740-742 Toorak Road, Hawthorn East Victoria Risk of Harm to Gardiners Creek - CARMS 47449-4 (PB Audit Report for Gardiners Creek), dated December 2009.

Golder and Associates (2009) Human Health Risk Assessment: 740 – 742 Toorak Road Hawthorn East Victoria - Underground Car Park (Golder, 2009)

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2. ON-GOING MANAGEMENT

On-Going Groundwater Monitoring Program

Groundwater conditions have been shown to be stable and no groundwater monitoring with regard to the risk of harm to Gardiners creek is considered necessary. The on-going groundwater monitoring program shall include biannual sampling for the purpose of monitoring human health risk associated with use of the underground car park.

The on-going groundwater monitoring program is summarised in the table below. The locations of groundwater monitoring wells are presented in Figure 1: Site Plan.

Task Location Frequency Analytes Sampling Method

groundwater MW5, MW19, MW10, August and cyanide (CN) [total], CN(free), CN(WAD), MicroPurge low sampling MW32, MW33, February thiocyanate, ammonia, nitrate, benzene, flow sampling MW34 toluene ethylbenzene and xylene (BTEX), total technique petroleum hydrocarbons (TPH), polycyclic aromatic hydrocarbons (PAHs), pH, total dissolved solids (TDS), dissolved oxygen, sulphate

Groundwater sampling should be undertaken in accordance with “Groundwater Sampling Guidelines” EPA Publication 669, April 2000 using a MicroPurge low flow sampling technique in wells with adequate groundwater recovery (MW10, MW32-34). Basement car park wells MW5 and MW19, due to short groundwater column height and slow recovery, have historically been sampled by purging groundwater using a disposable bailer and sampled after groundwater recovery and stabilisation (24 hours).

Analysis of collected groundwater samples is to be performed by National Association of Testing Authorities (NATA) accredited laboratories in accordance with recognised analytical methodologies.

The assessment should be undertaken with appropriate quality assurance / quality control procedures.

Reporting

As the risk to car park users is though the vapour intrusion exposure pathway, the primary contaminants of concern to be monitored are benzene and TPH C6 - C9. Should concentrations of these contaminants exceed the highest concentration monitored at that well since the beginning of 2008, results of groundwater sampling must be reported to a professional who is suitably qualified in the assessment of risk to human health (Risk Assessor) within 60 days of sampling. The Risk Assessor must also be reported to if ambient hydrocarbon odours are noted in the car park. Reassessment of risk in the form of air quality testing may be conducted based on evaluation by the Risk Assssor. Air quality testing and interpretation must be conducted using the same methodology undertaken during the Golder 2009 risk assessment.

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Table 1 presents the range of concentrations reported for each analyte at each well since the beginning of 2008.

Cessation of Monitoring Progam

The car park is considered in use as long as it can potentially be accessed by a person.

After four monitoring events (two years) groundwater data should be reviewed by a suitably qualified environmental professional. If it is concluded that the contamination status of groundwater remained stable during that time period, the monitoring program may cease.

Should the car park be decommissioned the monitoring program may cease and the GQMP revised accordingly. Should the car park be made available for any other land use, or be significantly modified, the GQMP must be revised in accordance with the relevant guidelines and legislation.

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3. LIMITATIONS

This GQMP has been prepared for the use of Leighton Properties Pty Limited, the appointed Environmental Auditor and whoever is the current title holder for the property located at 740-742 Toorak Road, Hawthorn East.

The application of this GQMP should be consistent only with the stated aims as outlined in the introduction of this report.

This report should be read in its entirety and shall not be reproduced except in full.

The information set out in the GQMP was considered accurate at the completion of Site investigation works.

The information set out in the GQMP is specific to those areas that formed part of the GQMP program.

This GQMP supersedes the GQMP dated February 2009 (Revision 5).

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TABLE 1 HISTORIC GROUNDWATER RESULTS

ANALYTE RANGES REPORTED JANUARY 2008 TO DECEMBER 2009 (mg/L) Monitoring Well TPHs BTEX PAHs Miscellaneous

TPH C6-C9 TPHs >C9 Benzene Toluene Ethyl benzene Xylene Total PAHs Naphthalene Benzo(a)pyrene Cyanide free Cyanide WAD Cyanide Thiocyanate

MW5 15 - 59 2.22 - 7.69 13 - 56 <0.1 - <1 <0.2 - 1.3 <0.2 - 0.89 0.56 - 7.4 0.56 - 7.4 <0.0001 - <0.01 1.1 - 3 0.0126 - 0.11 - <0.1 - 0.5

MW10 <0.2 - 0.051 0.492 - 0.899 <0.0029 - 0.016 <0.001 <0.001 <0.003 <0.001 <0.001 <0.001 0.27 - 0.54 <0.01 - 0.04 <0.1 <0.1 - 2

<0.001 - MW19 0.026 - 39 0.549 - 10.94 2.0 - 38 <0.001 - <0.5 <0.001 - 0.12 <0.001 - 0.56 <0.001 - 0.56 <0.001 1.0 - 13 <0.01 - 0.069 - <0.05 - 15 0.043

MW32 <0.02 0.447 - 3.396 <0.005 - 0.0015 <0.001 <0.001 <0.003 <0.001 - 0.003 <0.001 <0.001 0.44 - 1.1 <0.1 - 0.22 <0.1 <0.1 - <1

MW33 <0.02 - 0.037 0.563 - 2.232 <0.0005 - 0.2 <0.001 <0.001 <0.003 <0.001 <0.001 <0.001 0.33 - 0.96 <0.01 - 0.207 <0.1 <0.1 - 1

MW34 <0.2 - 0.049 0.352 - 1.224 0.0025 - 0.28 <0.001 <0.001 <0.003 <0.001 - 0.004 <0.001 <0.001 0.19 - 0.53 <0.01 - 0.03 <0.1 <0.1 - 1 Environmental Audit Report, 740-742 Toorak Road, Page 15 of 87 Hawthorn East, Victoria (CARMS#47449-2)

ENVIRONMENT PROTECTION ACT 1970 STATEMENT OF ENVIRONMENTAL AUDIT

I, John Throssell of Parsons Brinckerhoff, a person appointed by the Environment Protection Authority (‘the Authority’) under the Environment Protection Act 1970 (‘the Act’) as an environmental auditor for the purpose of the Act, having

1. been requested by Leighton Properties Limited to issue a certificate of environmental audit in relation to the site located at 740-742 Toorak Road, Hawthorn East, VIC 3123 being Lot 1 on TP120619U, Volume 09889 Folio 726 and Lot 1 on PS406054P, Volume 10376 Folio 882 (“the site”), owned/occupied by Leighton Properties.

2. had regard to, among other things, (i) guidelines issued by the Authority for the purposes of Part IXD of the Act,

(ii) the beneficial uses that may be made of the site, and

(iii) relevant State environment protection policies/ industrial waste management policies, namely, State Environment Protection Policies (SEPPs) Prevention and Management of Contamination of Land, Groundwaters of Victoria and Waters of Victoria (including Schedule F7, Waters of the Yarra Catchment).

in making a total assessment of the nature and extent of any harm or detriment caused to, or the risk of any possible harm or detriment which may be caused to, any beneficial use made of the site by any industrial processes or activity, waste or substance (including any chemical substance), and 3. completed an environmental audit report in accordance with Section 53X of the Act, a copy of which has been sent to the Authority and the relevant planning and responsible authority.

HEREBY STATE that I am of the opinion that The site is suitable for the beneficial uses associated with: commercial – consisting of a range of commercial and business activities such as office space and retail shops

industrial – consisting of utilities and a range of industrial activities such as manufacturing and processing of raw products; subject to the following conditions attached thereto:

Lot 1 (PS406054P) and other service easements along the Gardiners Creek margin of the site should be covered with hard pavements or a sufficient thickness of clean fill to ensure that the underlying soil or fill is not disturbed, eroded or otherwise accessible during normal uses associated with commercial or public open space related activities.

In the event that soil excavation works are undertaken within the service easements and in identified locations on Lot 1 (TP120619U), a soil management plan is required to control potential occupational health and safety and soil disposal issues. The easements and other areas of the site requiring soil management are illustrated in the attached site plan.

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Groundwater must not be extracted for any use other than clean-up, hydraulic containment or monitoring.

The Groundwater Quality Management Plan 742 Toorak Road, Hawthorn East (Bureau Veritas, 2009) prepared for the site and approved by EPA is to be implemented. The Groundwater Quality Management Plan details the following:

The design of a contingency system for hydraulic containment.

Installation of the contingency system including all fixed infrastructure.

The process for demonstrating the capability of the containment system to effectively control contaminant migration and impact on Gardiners Creek.

A monitoring program including groundwater and surface water, monitored wells, analytical program and methodology, monitoring frequency, program duration, review procedure, reporting requirements and roles and responsibilities.

Trigger conditions for implementation of the contingency system in accordance with EPA Publication 840 and a detailed description of subsequent actions in case the trigger is exceeded.

The Groundwater Quality Management Plan forms part of the environmental audit report and must be provided to current and all future owners/occupiers of the site.

By September 2009, complete an environmental audit under Section 53V of the Act to re-assess the risk of harm to Gardiners Creek caused by the discharge of polluted groundwater from the site

Maintenance of the ability to operate the contingency system until such time as otherwise instructed by EPA in writing.

The underground car park (former Gas Holder No. 1) must be backfilled or alternatively a human health risk assessment must be carried out prior to its on-going use if the structure is not backfilled. The risk assessment must be reviewed by an EPA appointed environmental auditor and recommendations made by the auditor must be implemented.

The condition of the site is detrimental or potentially detrimental to any (one or more) beneficial uses of the site. Accordingly, I have not issued a Certificate of Environmental Audit for the site in its current condition, the reasons for which are presented in the environmental audit report. The terms and conditions that need to be complied with before a Certificate of Environmental Audit may be issued are as set out as follows:

Removal of all contaminated soil and fill from the site.

Remediation of residual impacts in groundwater beneath the site.

Other related information

EPA Victoria has determined that groundwater has been cleaned up to the extent practicable subject to conditions listed above.

EPA Victoria has identified the site as within a Groundwater Quality Restricted Use Zone. Residual groundwater pollution comprises total petroleum hydrocarbons, benzene, toluene, ethyl benzene,

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xylene, cyanide, total polycyclic aromatic hydrocarbons, total cresols and metals. The observed metals are likely to be typical of the local aquifer.

Professional advice should be sought to assist in the appropriate management and/or disposal of residually impacted soil or fill.

Professional advice should be sought with regards to the integrity of building footings, basements or other structures that may intersect the groundwater.

This Statement forms part of environmental audit report Parsons Brinckerhoff, 740-742 Toorak Road, Hawthorn East, Victoria, Report no. M06347, 23 February 2009. Further details regarding the condition of the site may be found in the environmental audit report.

Dated: __23 February 2009

Signed:

John Throssell Environmental Auditor

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LEGEND

LOT 1 - TP120619U

LOT 1 - PS406054P

RESIDUAL IMPACT LOCATION

EASEMENTS

0 12.5 25 50 75

Full Size 1:1250 ; Half Reduction 1:2500 SCALE (m)

740-742 TOORAK ROAD, HAWTHORN EAST

C 17.02.09 DRAWING No. REVISED (PREVIOUSLY FIG 04) & KG CI LOCATION OF RESIDUAL SOIL IMPACTS SITE ADDRESS AMENDED REQUIRING ONGOING MANAGEMENT B 28.07.08 SITE BOUNDARY AMENDED, CAR PARK ADDED BJS TK A - PRELIMINARY ISSUE S.B. - C.I. - 2125047A HAZ FIG-05 C Environmental Audit Report, 740-742 Toorak Road, Page 19 of 87 Hawthorn East, Victoria (CARMS#47449-2)

Executive summary

This report has been prepared as required under Section 53W(1) of the 1970 Environment Protection Act (the Act)(1) in support of the attached Statement of Environmental Audit regarding the site known as 740- 742 Toorak Road, Hawthorn East, (“the site”). The development of the site is being undertaken by Leighton Properties (Vic) Pty Limited (“Leighton Properties”). The final land use is to be commercial, single owner/occupier.

Leighton Properties appointed Dr David Adams of Parsons Brinckerhoff (PB) to conduct a Statutory Environmental Audit (Audit) at this site. Dr Adams withdrew from the Audit in November 2007 and Mr John Throssell also of PB was appointed to complete the Audit of the site.

The purpose of the Audit was to aid in ensuring that any assessment and remedial works undertaken on the site deemed the site suitable for the intended use with respect to relevant legislation and guidelines.

This report has been prepared in accordance with Section 53X of the Act and other Victorian Environment Protection Authority (EPA) guidelines(1-5) and should be read in conjunction with the existing investigation reports.(6-22) Particulars of the audit are summarised in table below:

Summary of Audit Information

EPA file reference number 47449-2 Auditor John Throssell Auditor term of appointment 3 July 2007 to 2 July 2009 Name of person requesting audit Leighton Properties (VIC) Pty Ltd Relationship to premises Owner Date of request 2 November 2007 Date EPA notified of audit 2 November 20071 Completion date of audit 18 December 2008 Reason for audit Property transaction due diligence Current land use zoning Public Use Service and Utility (PUZ 1) EPA region Melbourne Metro Municipality Boroondara Dominant – Lot of plan Lot 1 on TP120619U, Volume 09889 Folio 726. Additional – Lot on plan(s) Lot 1 on PS406054P, Volume 10376 Folio 882. Site name Street No. 740-742 Street Name Toorak Street Type Road Suburb Hawthorn East Postcode 3123 GIS coordinates (GDA94) Latitude 37 50 45 .1855 Longitude 145 02 30.6218 Site area (hectares) 2.9321 ha

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Members and categories of Alex Blount (Human health risk assessment) support team utilised Alan Wade (Hydrogeology) Outcome of the audit Statement of Environmental Audit Further work or requirements Implementation of a groundwater quality management plan. Soil management plan for western margin of the site and areas of residual impacts. Nature and extent of continuing Elevated petroleum hydrocarbons (including total risk petroleum hydrocarbons (TPH), benzene, toluene ethylbenzene, and xylene (BTEX), polycyclic aromatic hydrocarbons (PAHs), total cresols, metals and free cyanide in groundwater pose a potential risk to Gardiners Creek, immediately adjacent to the site. PAHs and lead in residual soil pose a potential risk to site occupants. Site aquifer formation Shallow unconfined Quaternary aquifer Average depth to groundwater Approximately 0.1m below basement level of the car park (former gas holder No. 1) and approximately 6m below ground level across the site. Groundwater segment A2 (variable) Groundwater flow direction West, north west towards Gardiners Creek Past use/site history Industrial use Surrounding land use Residential, recreational/open space and commercial Proposed future use Commercial

1. Dr David Adams was engaged as Auditor on 1 March 2005. The audit was subsequently transferred to John Throssell on 2 November 2007.

The Auditor considers that due to the presence of contaminants in the groundwater onsite exceeding extractive use criteria for this area and the potential for impact to Gardiners Creek, and residual soil impacts, the site is not suitable for issue of a Certificate of Environmental Audit. However, the site is considered suitable for the proposed commercial use, subject to conditions indicated in the Statement of Environmental Audit.

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1. Introduction

Leighton Properties (VIC) Pty Ltd (Leighton) is currently redeveloping the property located at 740-742 Toorak Road, Hawthorn East being Lot 1 on TP120619U, Volume 09889 Folio 726 and Lot 1 on PS406054P, Volume 10376 Folio 882 (Figure 1, Appendix A) (“the site”). The 2.9231 hectare site had been used for many years as a gas storage facility, and is to be redeveloped for commercial use. Leighton engaged Kilpatrick & Associates Pty Ltd (Kilpatrick) to undertake environmental assessment works of the site. Kilpatrick previously performed environmental assessment and remediation works at the site under the instruction of Australand Holdings, which subsequently sold the site to Leighton. Kilpatrick have since undergone a name change and are now known as Bureau Veritas HSE Pty Ltd (BV).

Dr David Adams of Parsons Brinkerhoff (PB) was first engaged by the owner of the site in March 2005. Dr Adams terminated the audit in November 2007 and John Throssell was retained by the site owner to complete the audit. John Throssell was appointed an EPA Auditor under the Environmental Protection Act 1970 (Vic) on 24 July 2007.

1.1 Purpose

The purpose of undertaking a Statutory Environmental Audit is to ensure the site suitable for the intended use and this has been undertaken on a voluntary basis by the owners of 740-742 Toorak Road. The primary objective of conducting an Audit is to issue a Certificate of Environmental Audit (and accompanying audit report) for the site.

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2. Site details

2.1 Description

The site occupies an area of 2.9231 ha and is described as Lot 1 on Title Plan 120619U, (Volume 9889 Folio 726), representing the bulk of the audit area, and Lot 1 on Plan of Subdivision 406054P (Volume 10376 Folio 882) representing a small portion along the northwest margin of the audit area. Reserve 1 (for use by Melbourne Water Corporation) shown on PS406054P is not a part of the audit area. Copies of the Certificates of Title are provided in Appendix C.

The main features of the site are illustrated in Figure 2. (Appendix A). The site is roughly triangular in shape and is situated at the south east corner of the intersection of Toorak Road and the Monash Freeway. Immediately to the south and west of the site is the Gardiners Creek bicycle path and Gardiners Creek. To the east are residential homes along Kaikoura Road. Across Toorak Road, which forms the northern boundary of the site, are commercial properties including a service station to the north west and residential properties to the north east. A service station was previously located to the north east (corner Toorak Rd and Tooronga Rd). The former Melbourne Brick Company quarry and brick works was located approximately 300 meters to the east. Other historic uses of land around the site were residential, commercial and open space.

2.2 History

The site history shows that the site operated as a gas storage facility from the late 1890s to mid 1970s. The site was owned from the late 1800’s by the Metropolitan Gas Company. The first gas holder (Gas Holder No. 1) was constructed in 1892 on the south central edge of the site. Although gas was not manufactured on the site, gas works related waste may have been used as fill material. Gas Holder Nos. 2 and 3 were constructed in 1926 to the north west and south east of Gas Holder No. 1. The gas holders had a capacity of 6.5 million cubic feet and distributed gas to the south and south eastern suburbs. Based on existing plans, the gas holders were constructed with 0.760m brick outer walls with 15mm of render on the interior.

Between 1945 and 1971, the gas holders were decommissioned, with Gas Holder No. 3 being completely removed. Some additional facilities were constructed on the site during this period including: offices, stores, a garage and tennis courts with a club house. During this period infilling occurred at the site to prevent flooding from the adjacent Gardiners Creek.

In 1980, Multinet (formerly the Gas and Fuel Corporation), the owner of the site, used the site as a District Service Centre for gas distribution and customer service. During this period, Gas Holder No. 1 was converted into a two – level underground car park. The car park was erected by constructing a brick inner wall and a reinforced concrete ramp structure on pilings in the gas holder. The remaining Gas Holder No. 2 was in-filled and various infrastructure was installed at the site including: operations & service depot, car service maintenance workshop, underground storage tanks, fuel bowsers, sump oil tank, above-ground LPG tank storage sheds were constructed on the north west section of the site.

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Between 1995 and 1996 some site buildings were converted for use as the Tooronga Office Complex (corporate office for GASCOR, formerly the Gas and Fuel Corporation) and infrastructure was removed including the fuel station and underground storage tanks. Site use as the District Service Centre continued until 1998, when the site was acquired by United Energy, which subsequently sold the site in 1999 to Australand Holdings. Australand planned redevelopment of the site and completed demolition of site structures, except for the basement car park constructed within former Gas Holder No. 1. Australand also constructed a temporary building containing a development display model on the site. In February 2005 the site was sold to Leighton properties.

It is noted that Melbourne Water may have used the north west corner of the site (within the Melbourne Water reserve) as a chlorinator plant. The years of operation are not known and no further information was available.

Previous site activities/infrastructure likely to have impacted the site may be summarised as:

gas storage in sealed (possibly oil or tar) concrete holding tanks infilling with gas works waste fuel and waste storage (petrol, diesel and oil USTs) use of sumps and pits for collection of car service waste underground services aggregate, soil, gravel and hot mix storage electrical substation and subsurface asbestos cement piping chlorinator plant. Current site infrastructure includes the following:

underground car park (former Gas Holder No. 1) display model building gas and electrical services along the western boundary.

2.3 Planning considerations

The site is currently zoned Public Use Service and Utility (PUZ 1) and the land is proposed to be developed for commercial use. The immediate neighbouring land uses are:

Toorak Road and across Toorak Road, commercial properties to the north including a service station. Gardiners Creek, a bicycle path and Citilink Freeway reserve to the south and west. Residential properties to the east.

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2.4 Geology and hydrogeology

2.4.1 Geology

The regional geology as reported in the Environmental Site Assessment (ESA) Report(12) consists of Quaternary-age low-level alluvial beach sands. In the immediate proximity of the site to the east are Lower to Middle Silurian-age sedimentary deposits of the Dargile Anticline Formation comprised of massive siltstones interbedded with thin sandstones. Along the sites western fringe over Gardiners creek are upper Silurian-age sedimentary deposits consisting of laminated and current bedded sandstones interbedded with massive siltstones and shales. Field investigations confirmed that the natural sediments underlying the site were of either alluvial or siltstone origin. Sediments nearest to Gardiners Creek on the western edge of the site exhibited alluvial characteristics with a high proportion of sandy sediments. Weathered siltstone was intersected at a depth of between 10 and 13 metres below ground level, indicating the presence of the Silurian- age sedimentary deposits of the Dargile Formation. The presence of fill material varied considerably across the site with the deepest areas (up to 5.4 metres) located along Gardiners Creek on the western edge of the site. The fill material was used to backfill former Gas Holders No. 2 and No. 3. The geology of the site is summarised in Table 2- 1.

Table 2-1: Site geology

Characteristic Description Local geological Fill overlying Quaternary age alluvial sediments comprising sand, silt, clay units and minor gravel, and Silurian Dargile Formation sediments. General Site 0 –5.6 mBGL: FILL: Ranges in thickness, but is generally between 1m and Profile: 2m thick. The fill material is deepest on the western portion of the site. 0.3m – 4.6 mBGL: SAND/SILT: Grey to light grey sands, poorly sorted and dark brown to grey silts. Ranges in thickness, but is generally 1m thick. 0.3m – 10.1 mBGL: CLAY: Grey-brown, moderate to firm. Interbedded with sand lenses located between 4m and 10mBGL of thickness between 0.2 and 2.8m. 2.2m – 11.5mBGL: SILTSTONE: weathered.

2.4.2 Hydrogeology

The site is located adjacent to Gardiners Creek which drains an area extending towards Mount Waverly in the east and Box Hill to the northeast, and discharges to the Yarra River approximately 1.8 km north of the site. The shallow valley containing Gardiners Creek is incised into the Silurian Dargile Formation which forms the basement rock for much of the eastern suburbs of Melbourne. The valley is also partially filled with recent alluvial deposits, which based on local investigation data, form a series of interbedded silts, sands and clays.

Both the Dargile Formation and the shallow alluvial deposits host local aquifers. Groundwater is present in the Quaternary deposits within sandier horizons, and although these saturated intervals appear separated by more clayey aquitards, groundwater investigations at the site suggest they are hydraulically connected. No investigation of underlying Silurian aquifer has been undertaken at the site, although its presence has

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been confirmed at a depth of approximately 13m BGL (below ground level). Groundwater flow appears to generally follow topography in the vicinity of the site, with discharge occurring into Gardiners Creek. Local modification of groundwater flow may have resulted from long-term groundwater abstraction from the sump in the base of the underground car park (former gas holder No. 1).

Groundwater at the site has been described in the ESA(12) as being present in upper and lower (second uppermost) aquifers. Monitoring bores are screened across the aquiclude and the sand aquifer in several cases. It is therefore reasonable to assume that site bores represent a zone that includes the interbedded upper sediments and the sand layer beneath these sediments. It is concluded that the groundwater bores installed at the site cross the interbedded clay/silt and sand layers and these upper sediments including the lower sandy layer may be termed the aquifer of interest at the site.

The hydrogeology of the site is summarised in Table 2-2 and groundwater elevation contours are illustrated in Figure 3 (Appendix A).

Table 2-2: Site hydrogeology

Characteristic Description Depth to groundwater (May Approximately between 0.1 (bore located within former gas holder 2008): No. 1) and 6.4 metres below top of casing within the clay aquifer.

Direction of groundwater Generally to the west and northwest towards Gardiners Creek from flow: the site. Comparison of water trends in Gardiners Creek with local groundwater trends also suggests that the creek recharges groundwater immediately adjacent to the creek. Hydraulic conductivity Measured site hydraulic conductivity ranged from 4.04x10-5 to (April-May 2008): 8.2x10-4 cm/sec in pumping bores. Nearest surface water body: Gardiners Creek, immediately to the south and west. Total dissolved solids (TDS) On site: 640 mg/L – 6,400 mg/L (May. 2008): Offsite: 670mg/L – 5,900 mg/L

Groundwater pH (May Groundwater pH ranged from 6.7 to 8.3. 2008): Groundwater type (March The overall groundwater type is Na-Cl with sulphate (MW4, MW13, 2003): MW17, MW20, MW22) or bicarbonate (MW10, MW11, MW19, MW23). Nominated groundwater Groundwater has been classified as Segment A2 as it segment: encompasses the lowest TDS concentration for the site. It is noted that potential sources of recharge at the site include leaking drains and sewers. Longer term monitoring may provide better indication of the appropriate segment for the site. Groundwater use: Nearest registered groundwater bores (Bore id Nos. 88726 and 133811) were located approximately 1km south east and south of the site, potentially up hydraulic gradient (12). The bore to the south east reported a standing water level of 27metres and was registered for domestic purposes. The bore to the south was listed as an investigation bore and was screened between 9mBGL and 12mBGL. No standing water level was reported.

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2.4.3 Surface water

Gardiners Creek is the nearest surface water body to the site and is located immediately adjacent to the site along its south and south west boundary.

Creek gauging has been performed quarterly from February 2005 to May 2008(16-22) and was historically performed relative to a star picket placed along the edge of the creek. Long term creek levels appear relatively constant, increasing somewhat from January 2006.

Flow within the creek is variable irrespective of the time of year. Low flow and high flow conditions did not correlate with seasonal changes, and are likely to be related to individual rain events or other anthropogenic discharge events. Low and high flow conditions could not be correlated to the data due to the absence of flow data during sampling and gauging.

There appears to be some connectivity between Gardiners Creek and the screened aquifer based on the groundwater relative levels and gauging of the creek level. The two aquifers also have similar lithologies based on the presence of silty clay, clay and sand.

Overall, the creek and groundwater elevation data indicate little fluctuation over time with groundwater flowing towards the creek. It is considered that shallow groundwater is discharging to Gardiners Creek along the western and south western boundaries of the site.

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3. Beneficial uses

A Statutory Environmental Audit, under the terms of the Environment Protection Act 1970(1), means:

“a total assessment of the nature and extent of any harm or detriment caused to, or the risk of any possible harm or detriment which may be caused to, any beneficial use made of any segment of the environment by any industrial process or activity, waste, substance (including any chemical substance) or noise”.

Therefore, in conducting the Statutory Environmental Audit, all potential beneficial uses of the site were considered including potential beneficial uses of the land, groundwater and surface water, as identified in relevant State Environment Protection Policies. The following potential beneficial uses have been considered in this Audit:

3.1 Land

The beneficial uses for each segment of land that need to be protected as defined in the SEPP Land(23) are as follows:

Table 3-1 Protected beneficial uses of land

Beneficial use Land Use

l / e Sensitive Use

e a l

n r c i s a o a c & u i e i

t r r t p v l t

s y e r a s - r u t s k

e i e e r h c m u n r s i s a h g r d e c e i t n m P g n e p e o R H I O A d R O C

Maintenance of ecosystems Natural ecosystems Modified ecosystems Highly modified ecosystems Human health Buildings & structures Aesthetics Production of food and flora

It should be noted that production of food and flora is not listed as a beneficial use to be protected where the planning segment is commercial (as applicable to this site), industrial, recreation/open space, or high-density residential use.

3.1.1 Soil assessment criteria

The assessment criteria have changed over the course of the assessments due to changes in proposed future use. The following assessment criteria were adopted by Kilpatrick & Associates in 2004 in consultation with the Auditor for the assessment of soil:

NEPM Health Investigation Levels: NEPM HIL-F (“industrial/commercial setting)(24). NEPM Ecological Investigation Levels (Interim Urban): NEPM-EIL(24).

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NSW EPA Guidelines for service station sites(25) – for sensitive land use (where no NEPM criteria are available (e.g. TPH, BTEX). Table 3-2 below lists the criteria used to assess impacts to beneficial uses of the land.

Table 3-2: Soil assessment criteria

Analyte Protection of Maintenance of Protection of Human Health Highly Modified Building & (Commercial/Indu Ecosystems Structures strial) (mg/kg) (mg/kg) (mg/kg) Primary adopted NEPM (1999) NEPM (1999) EIL investigation reference HIL-F C TPH C6-C9 65 - - C TPH C10-C36 1000 - - Benzene 1 C - - Toluene 1.4 C - - Ethyl Benzene 3.1 C - - Total Xylenes 14 C - - Total PAHs 100 - - Naphthalene - - Pyrene - - Benzo(a)pyrene 5 - - Total Phenols 42500 - - Arsenic 500 20 - Barium - 300 - Beryllium 100 - - Cadmium 100 3 - Cobalt - - - Chromium 500 400 - Copper 5000 100 - Mercury 75 1 - Molybdenum - - - Nickel 3000 60 - Lead 1500 600 - Antimony - - - Selenium - - - Tin - - - Vanadium - 50 - Zinc 35000 200 - Iron - - - Total VHCs - - - Aldrin + Dieldrin 50 - - Chlordane 250 - - DDT+DDD+DDE 1000 - - Heptachlor 50 - -

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Analyte Protection of Maintenance of Protection of Human Health Highly Modified Building & (Commercial/Indu Ecosystems Structures strial) (mg/kg) (mg/kg) (mg/kg) Total PCBs 50 - - Sulfate - - 2000D pH - - >4.5E -- No investigation level available A NEPM (1999) – Commercial/industrial ‘F’ (24) B NEPM (1999) – Ecological Investigation Level (24) C NSW EPA Guidelines for Service Station Sites (25) D NEPM (1999) – Interim Urban for protection of built structures (24) E AS2159 (1995) – Piling Design and Installation: Severe to very severe soil exposure conditions for concrete piling (42)

3.2 Groundwater

Groundwater quality at the site is variable and Segment A2 has been adopted for the site to encompass all observed groundwater salinities at the site. The SEPP GoV(26) lists the beneficial uses of groundwater that need to be protected as follows:

Table 3-3: Groundwater protected beneficial uses

Beneficial use Segment (mg/L) A1 A2 B C D (0 -500) (501- (1,001- (3,501- (>13,000) 1,000) 3,500) 13,000)

Maintenance of ecosystems

Potable water supply - desirable - acceptable Potable mineral water supply Agriculture, parks and gardens Stock watering Industrial water use Primary contact recreation (e.g. bathing, swimming) Buildings and structures

3.2.1 Groundwater assessment criteria

The following assessment criteria were adopted by Kilpatrick & Associates and BV during the assessment of groundwater:

State Environmental Protection Policy (SEPP) Groundwaters of Victoria(26). NHMRC and ARMCANZ Australian Drinking Water Guidelines, 1996(27). Australian Water Quality Guidelines for Fresh and Marine Waters, ANZECC 1992(28).

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Variation to the SEPP (Waters of Victoria) – Schedule F7 Waters of the Yarra Catchment 1999(29).

ANZECC Water Quality Guidelines for Fresh and Marine Waters, 2000(28). NEPM 1999 criterion for the protection of Aquatic Ecosystems(24). Dutch Intervention Guidelines (30). The adopted criteria were considered appropriate to make an assessment of the potential impact to the beneficial uses of groundwater on site.

Table 3-4 below lists the relevant groundwater assessment criteria adopted for the chemical of concern to protect the beneficial uses relevant for Segment A2. Preference is given to Australian guidelines over any overseas guidelines, and in compliance with the SEPP(26), precedence to ANZECC 1992 was given over the more recent ANZECC 2000 guidelines.

Table 3-4: Groundwater and surface water investigation levels in micrograms per litre (µg/L)*

Potable Irrigation Fresh water Primary Water - (Agriculture, Beneficial Use 95% Stock Industrial Contact Acceptable parks & Protection Recreation gardens) Primary adopted ANZECC ANZECC ANZECC ANZECC ANZECC ANZECC assessment 1992(28) 1992(28) 1992(28) 1992(28) 1992(28) 2000(31) criteria

pH 6.0 -8.5A 6.5-8.5E 4.5-9.0 - 0.0025- 6.5-8.5 0.0105G TDS (mg/L) <1000 A 1000 0-3500 3000 50-<35000G 1000

D TPH C6-C9 150 - - - - - D TPH C10-C36 600 - - - - - Benzene 300 10 - - - 10 I Toluene 300 800F - - - - Ethylbenzene 140 300F - - - - Xylenes 200B 600F - - - - Total PAHs 3 - - - - - B(a)P 1E 0.01 - - - 0.01 I Naphthalene 16B - - - - - Total Phenols 50 - - - - - Phthalates - - 0.6 - - 10 H (di(2)ethylhexyl) Cyanide (total) 5 A 100 - - - 100 I Nitrate (as N) 10,000G <0.01- 700 B - 30000 10,000 I <0.02H Ammonia (as N) 10 Trace- 20-30 A - - 10 I 0.0007GI Chlorinated 70 D 10E - - Slight-<0.01 - Hydrocarbon G

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Potable Irrigation Fresh water Primary Water - (Agriculture, Beneficial Use 95% Stock Industrial Contact Acceptable parks & Protection Recreation gardens) Antimony 0.03 3F - - - - Arsenic 50A 7F 50 G 500 - 50 I Barium 500 D 0.001 1000 - - 1000 Beryllium 4A - - 100 - - Boron 370 B 0.001 1000 5000 - 1000 Cadmium 0.2 A 5 5 G 10 - 5 I Chromium 10 AC 50 50 G 1000 - 50 I Copper 2 A 200F 1000 G 500 0.00001- 1000 I <0.005G Cobalt 100 D 50 - 1000 - - Lead 1 A 50 50 G 100 - 50I Manganese 1900 D 100 100 G Not 0.00003- 100 I sufficiently <0.005G toxic Mercury 0.05A 1F 2 2 - 1 Molybdenum - 50 F 10 10 - - Nickel 15A 20 F 200 1000 - 100 Selenium 5 A 10 F 20 20 - 10 Tin - 0.022L - - - - Zinc 5 A 5 2000 20000 0- 5000 AcceptableG

* Except where noted - No investigation level available. A SEPP Schedule F7 Waters of the Yarra Catchment (Toxicants) (29) B ANZECC 2000 – Freshwater Aquatic (31) C Chromium VI D Dutch 2000 – Intervention level (30) E NHMRC/NRMMC 2004 – Australian Drinking Water Guidelines - Aesthetic (32) F NHMRC/NRMMC 2004 – Australian Drinking Water Guidelines - Health (32) G ANZECC 2000 – Primary Contact Recreation (31) H ANZECC 2000 - Nitrate concentrations less than 400 mg/L in livestock drinking water should not be harmful to animal health. Stock may tolerate higher nitrate concentrations in drinking water, provided nitrate concentrations in feed are not high. Water containing more than 1500 mg/L nitrate is likely to be toxic to animals and should be avoided. Concentrations of nitrite exceeding 30 mg/L may be hazardous to animal health(31). I Variable dependent upon the industrial process J Food processing industry K Carbon Tetrachloride L USEPA Region 9 – Tap Water2004 (41)

The guidelines and relevant beneficial uses adopted in the Bureau Veritas Environmental Audit(22) report to assess groundwater quality for the site are listed below. Precedence to ANZECC 1992 was given over the more recent ANZECC 2000 guidelines.

Maintenance of ecosystem – ANZECC 2000 freshwater ecosystem 95% protection(31). Potable water supply (acceptable) – ANZECC 1992 raw drinking water(28).

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Agriculture, parks and gardens – ANZECC 1992 irrigation water quality(28). Stock watering – ANZECC 1992 livestock watering(28). Industrial water use – ANZECC 1992 industrial water(28). Primary contact recreation – ANZECC 1992 raw drinking water, 2004 NHMRC drinking water - health(28). Buildings and structures – No criteria, “groundwater shall not be corrosive to structures”.

3.3 Surface water

The beneficial uses of surface water that need to be protected are considered those associated with freshwater ecosystems, as specified in the State Environment Protection Policy (SEPP) (Waters of Victoria, Schedule F7 – Waters of the Yarra Catchment)(29), The site is within the urban waterways segment.

The protected beneficial uses for the urban waterway segment specified in Schedule F7 of the SEPP are:

modified ecosystems passage of indigenous fish maintenance of indigenous riparian vegetation water based recreation (primary contact, secondary contact, aesthetic enjoyment) commercial and recreational use of edible fish and crustacean agricultural water supply (stock watering and irrigation) commercial purposes (navigation and shipping, industrial water use).

3.3.1 Surface water assessment criteria

The following assessment criteria were adopted by Kilpatrick & Associates and BV during the assessment of surface water:

NHMRC and ARMCANZ Australian Drinking Water Guidelines, 2004(32). Australian Water Quality Guidelines for Fresh and Marine Waters, ANZECC 1992(28). Variation to the SEPP (Waters of Victoria) – Schedule F7 Waters of the Yarra Catchment 1999(29).

ANZECC Water Quality Guidelines for Fresh and Marine Waters, 2000(31). Dutch Intervention Guidelines (30). In the absence of surface water on the site, the adopted criteria were considered appropriate to make an assessment of the potential impacts to Gardiners Creek and are the same as those for groundwater (protection of aquatic ecosystems) provided in Table 3-4 above.

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3.4 Consideration of beneficial uses

For this Audit, all the beneficial uses as listed in the State Environment Protection Policies were considered. Discussions on the relevance and consideration of the beneficial uses of the site that had been or may be potentially impacted by the contamination identified on site are provided in Section 4.3.

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4. Investigation and remedial works

4.1 Soil investigations

During the various phases of site assessment, potential sources of site contamination were identified from the storage/disposal of gas works waste (tars, sludges, lampblack, light oils and spent oxide waste) and automobile maintenance infrastructure (including underground storage tanks (USTs), fuel lines and a sump oil tank). Soil assessments were performed between 1993 and 2005. The soil assessments identified contamination to be mainly due to the presence of metals; total petroleum hydrocarbons (TPH); benzene, ethyl benzene, toluene and xylene (BTEX); phenols; cresols; cyanide; and polycyclic aromatic hydrocarbons (PAHs) mainly in fill across the site at depths between 0 and 2.5mBGL. Impacts to natural soil was also present, but was limited in extent.

The majority of the soil contamination was identified in the following areas (refer Figure 2, Appendix A):

Within shallow fill material across the site to a depth of approximately 1m below ground level (BGL) Around the former UST tank farm (south of Gas Holder No. 1) In the north central section of the site at the former workshop and sump to depths of up to 1.5mBGL On the south eastern area of the site at the former compound store (to the north west of Gas Holder No. 3) Off the east, north east portion of Gas Holder No. 2 to a depth of approximately 2.5mBGL The southern area of the site to a depth of approximately 0.5mBGL The north eastern area of the site (presence of fuel pipe infrastructure) to depths of up to 1.0mBGL Around the substation near the northern site boundary Around the Venturi Pit. Fill material across the site ranged in depth from approximately 0 to 2mBGL, being greatest along the Gardiners Creek margin of the site. Gas works waste was identified within the fill material and was easily identifiable as coke, ash, charcoal and slag. Other components of the fill material included gravel, sand and clay. Some demolition rubble such as bricks and minor asbestos cement fragments were also present in the fill material. The fill material was found to have elevated PAH concentrations above NEPM F, and metals concentrations (including As, Cu, Ni, Pb and Zn) below NEPM F criteria. Cyanide concentrations were also elevated in the fill material but below the NEPM F criteria.

Elevated PAH concentrations above NEPM F were identified mainly in surface fill to a depth of approximately 1.0 metres. Deeper PAH impacts in fill material were identified on the north and east sides of Gas Holder No. 2 at depths between 1.5 and 3.65 mBGL with concentrations ranging from 140mg/kg and 15,000 mg/kg. At the compound store area, a

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TPH concentration of 280 mg/kg was identified at 2.0mBGL. At Gas Holder No. 1 a PAH concentration of 1400mg/kg was reported at 2.0mBGL. Benzo (a) pyrene concentrations were similarly elevated.

Isolated areas of elevated TPH C10-C36 were identified at the UST tank farm

(74,000mg/kg TPH C10-C36), near the former substation north east of the workshop

(2,400mg/kg TPH C10-C36), off the eastern portion of Gas Holder No. 2 (14,000mg/kg

TPH C10-C36), and to the north of Gas Holder No. 2 (29,000mg/kg TPH C10-C36). Benzene (2.8mg/kg) and toluene (5.1mg/kg) exceeded the NSW EPA guidelines at the UST tank

farm. TPH C6-C9 was detected above the NSW EPA guidelines on the eastern portion of

Gas Holder No. 2 at 99mg/kg. No other elevated concentrations of TPH C6-C9 or BTEX were identified.

Analytical results indicated impacts to the natural silt or clay were below the NEPM F or other relevant criteria.

A total of nine soil investigation reports have been reviewed for the site. The reports and scope of the investigations are provided in Table 4-1 below.

Table 4-1: Summary of previous site soil investigation works

Report Scope of Works CMPS&F, Department of Treasury and Four bore holes, six test pits and three hand Finance, Site Investigation, October 1997.(6) auger bores were advanced across the site. Three of the bore holes were installed as groundwater bores. The report reviewed was incomplete and therefore was not considered for the purposes of the Audit. GSB Land Remediation Division, Multinet, Soil The purpose of this assessment was to Contamination Assessment of Proposed investigate the contamination status of soil Parking Areas, January 1998. (7) beneath two car park areas for proposed site works. The parking areas assessed were located on the north west quadrant of the site. Grid based test pit sampling was performed. Fill material was noted in the bore logs to a depth of approximately 0.8mBGL. Laboratory analytical results indicated elevated concentrations of PAHs and arsenic. The soil was classified into waste categories for disposal. No record of disposal is provided. Egis Consulting, Environmental Site Soil sampling was performed at 20 locations Assessment Report. September 1999. (8) across the site. No groundwater investigations were performed. Composite soil samples were analysed and the results were therefore not considered further for the purposes of the audit. Fill material was identified in one bore hole at a depth of 4mBGL (BH1 located immediately to the south west of former Gas Holder No. 1). Egis Consulting, East Supplementary Soil sampling was performed at 14 locations Environmental Site Assessment Report. across the site. The maximum depth of soil February 2001. (9) bores was 3mBGL. Three groundwater monitoring bores were installed. Fill material was present at depths of up to approximately 2mBGL. Concentrations of PAHs and metals exceeded the NEPM F investigation levels. Further soil sampling was recommended to delineate site contamination.

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VEMCO Environmental Services, Site History The VEMCO report provides a site history, Appraisal & Assessment Summary, October review of previous assessment reports findings. 2001. (10) Kilpatrick & Associates Pty Ltd, Environmental The site history is reviewed and a soil Status Report. May 2002. (11) investigation consisted of advancement of 56 soil bores across the site. The bores targeted areas including the three former Gas Holders, former car maintenance centre including USTs, sumps and fuel lines, previously identified impacts. The results indicated significant PAH impacts and petroleum hydrocarbon impacts across the site. Kilpatrick & Associates Pty Ltd, Environmental In May to September 2002 further site soil Site Assessment, March 2003. (12) investigations were performed at the site to investigate previously identified impacts. The targeted locations were: test pits around the outer perimeter of former gas Holder No. 1; South west UST investigations; test pits and bores in the vicinity of former Gas Holder No. 3; trenching along the central eastern area of the site; boreholes and test pits in former Gas Holder No. 1 and trenching in the base of former Gas Holder No. 2. Hot spot excavations were performed to remove chemicals of concern at the following locations: Hoist pit excavation; stabilised tank pit (north of the underground car park); north and east hoist pit excavations - BH75, BH76, BH76A, BH72, TP3; BH24 – north east corner of the site; eastern section of site at BH63, BH23; South west UST pit excavation; south section of the site at BH28 and BH40; and south east excavation adjacent to former Gas Holder No. 3. Validation samples were collected where possible. However some excavations were not validated. A total of approximately 3,000 cubic metres of soil was disposed to landfill. Kilpatrick & Associates Pty Ltd, December Reporting of revised development plans (to 2003. (13) residential (no longer valid)); amendments to analytical results tables to include all previous site works; stockpile sampling and disposal discussion reporting 2,000 cubic metres of soil disposed as Low Level Contaminated Soil based on existing soil data points, stockpile sampling and visual observation; chemical status of backfill material; proposed further removal of impacted soil. Groundwater investigations were also included in this report (refer Section 5). Kilpatrick & Associates Pty Ltd, July 2004. (14) Consideration of soil remediation options; estimation of contaminant mass remaining post soil excavation and disposal; estimate of cost to remove basement car park. Groundwater investigations were also included in the report (refer Section 5) Kilpatrick & Associates Pty Ltd, September Soil excavation and validation works. 1,000 2005(16) cubic metres of soil was disposed to landfill. Four locations were noted as remaining “hot spots”: BH57 NW-2, BH58 SW-3, BH58 B/0.8-2, BH70 WW-2. These locations could not be further excavated due to subsurface/adjacent structures or plants.

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4.2 Soil remediation

Soil remediation works consisted of removal and validation of impacted locations. Excavations were commenced in May 2002 and included: the hoist pit excavation, stabilised tank pit excavation, excavation east of Gas Holder No. 2; area adjacent to the northern substation; north eastern UST area; former workshop area; north of the service depot; east of the compound store area; South west UST pit; south section of site. Subsequent excavations were performed in 2005. The extent of excavations and levels are provided in Figure 4, Appendix A. The excavations were performed to remove impacted areas above EPA Low Level Contaminated Soil criteria (Environment Protection (Prescribed Waste) (Amendment) Regulations 2000), that were in place at the time of the assessment. Several locations could not be validated due to the presence of infrastructure or mature trees which prevented further excavation. These locations are illustrated in Figure 5 and are discussed further in Section 4.5 Final Condition of the Site.

4.3 Management of excavated materials/stockpiles

Excavated soil was assessed for disposal based on existing soil data points, stockpile sampling and visual observation and either stockpiled for sampling or immediately placed in EPA licensed vehicles for off-site disposal. All excavated soil material was sampled adequately with respect to existing EPA guidelines. The stockpiled material classified as prescribed waste was removed from the site. Transporting of the excavated soil was undertaken by a licensed contractor holding an EPA permit to transport contaminated soil and all material was documented with EPA Waste Transport Certificates.(13,17). Contaminated material was disposed according to EPA guidelines.

The amount of impacted soil that was classified and removed to landfill was as follows:

Prescribed Waste, Contaminated Soil – 2,500 m3 Prescribed Waste, Low Level Contaminated Soil – 1,500 m3.

4.4 Groundwater investigations

Thirty five groundwater monitoring wells and five recovery wells were installed on and adjacent to the site over the period 1997 to 2008, with the majority of wells generally installed within the upper 3m of the saturated aquifer. Three bores (MW17, MW22, and MW23) were installed in the lower sediments of the aquifer.

Twelve rounds of groundwater monitoring have been completed by Kilpatrick & Associates or BV, the latest in May 2008(22). In 2008, additional bores were installed along the western site boundary including recovery wells as a part of the contingency plan for hydraulic containment of impacts moving towards the creek. The details of the hydraulic containment system are provided in the Groundwater Quality Management Plan Reference Document(37).

A summary of works completed is shown in Table 4-2.

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Table 4-2: Summary of previous site groundwater investigation works

Date and source Description of groundwater investigation Groundwater Wells Surface works monitoring installed Water round Sampling Round Egis Consulting, Installation and sampling of three Egis 2001 BH28 None February 2001: groundwater monitoring wells to investigate BH29 Section 5.1.(9) potential groundwater contamination and BH30A groundwater flow direction, which also involved some soil sampling. Groundwater was reported at depth of between 5mBGL and 7.5mBGL. Although bores were not surveyed to height datum. It was considered that groundwater flow was to the west towards Gardiners Creek. Kilpatrick & Five groundwater bores were installed. Round 1 MW1 MW2 None Associates, May However MW2 produced insufficient water for MW3 MW4 2002(11) sampling. Groundwater was encountered MW5 between 5mBGL and 7.5mBGL. Kilpatrick & This investigation included the installation of Round 2, 3A, 3B MW6 MW7 June and Associates, March additional 13 groundwater monitoring wells (A MW8 October 2003 and Kilpatrick total of 19 groundwater wells variously MW10 2002 & Associates, sampled). MW11 December 2003 MW12 (included MW13 amendments to MW16 March 2003 report) MW17 (12,13) MW18 MW19 MW20 MW21 Kilpatrick & Installation of four groundwater monitoring Rounds 4 and 5 MW24 Associates, bores in March 2003 prior to Round 5 MW25 December 2003(13) sampling. Investigation into Gardiners Creek MW26 realignment indicated that the creek was not MW27 lined with any substrate. The ionic composition of the groundwater was investigated and this indicated that the upper and lower aquifers were separate systems. Hydraulic conductivity measurements were taken in selected Upper and Lower aquifer bores using a slug and data loggers to capture the change in standing water levels. Fate and transport modelling was performed for cyanide and benzene flow from the site into Gardiners Creek. Kilpatrick & Well installation works. Low recharge was Round 6 MW28 11 March Associates, July noted in bores during groundwater sampling MW29 2004 2004(14) and some analytes could not be analysed due MW30 to insufficient sample. All available bores were MW31 sampled. Surface water sampling was performed on 11 March 2004. Kilpatrick & Sediment sampling was performed at the Round 7 None February, Associates, surface water sampling points at Gardiners March, September 2005(16) Creek. Surface water sampling was performed April, May, monthly over 6 months. Groundwater June and sampling was performed in July 2005 at ten July 2005 bore locations (MW1, MW3, MW10, MW13, MW19, MW20, MW29, MW17, MW22, MW23). An appraisal was made of the basement car park sump in former gas holder

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Date and source Description of groundwater investigation Groundwater Wells Surface works monitoring installed Water round Sampling Round No. 1. Gauging of creek levels was performed. Kilpatrick & Groundwater monitoring was performed in Round 8 None August – Associates, October 2005. Surface water sampling was October November 2005(17) also performed. Gauging of the basement car 2005 park sump continued. Gauging of creek levels was performed. Kilpatrick & Groundwater monitoring was performed in Round 9 None November, Associates, March January 2006. Surface water sampling was December 2006(18) performed. Gauging of creek levels was 2005, performed. January 2006

Kilpatrick & One round of groundwater sampling at 9 Round 10 None March Associates, July groundwater bores and quarterly surface 2007 2007(21) water sampling and gauging at Gardiners Creek. Bureau Veritas Groundwater sampling of 28 available Round 11 and MW32- August 2008(22) groundwater bores / recovery wells. Quarterly 12 MW34, 2007, Dec surface water sampling and gauging at RW1-RW5 2007, Gardiners Creek Reinstallati February on of 2008, May MW10 and 2008 MW20

In addition to the groundwater investigations detailed above, a Groundwater Quality Management Plan (GQMP)(23) and Hydraulic Containment System technical document (HCSTD)(37) have been prepared for the site. These documents are attached as Appendix H. As a part of EPA’s conditional clean-up to extent practicable (CUTEP) determination a GQMP has been prepared for the site to monitor site impacts and prevent impacts from reaching Gardiners Creek. The HCSTD describes the hydraulic containment system that has been constructed on site as a part of the EPA’s CUTEP determination (refer EPA letter Appendix D). The HCSTD provides details on the system operation parameters.

Key groundwater monitoring results relating to benzene and cyanide from the May 2008 groundwater monitoring event are illustrated in Figure 6, Appendix A. Table 4.3 below provides a summary of groundwater impacts in relation to adopted relevant beneficial use criteria and more detail on groundwater conditions at the site can be found in Appendix E.

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Table 4-3: Summary of groundwater results exceeding beneficial use criteria (May 2008)

Beneficial use Analyte Max. Maintenance Potable water Agriculture, Stock Industrial Primary Buildings Sample locations conc. of supply - Parks and watering water use contact and exceeding Maintenance (mg/L) ecosystems acceptable gardens recreation structures of Ecosystems criteria

TPH C6–C9 43 Y ------MW5, MW19, MW24, RW3, RW5 TPH C -C MW5, MW19, MW20, MW24, MW34, 10 36 3.914 Y ------RW2, RW3, RW5 Benzene 42 Y Y - Y - Y - MW5, MW19, MW24, RW5, RW3 Toluene 0.045 Y Y - - - Y - MW24 Ethylbenzene 0.51 Y Y - - - Y - MW5, MW24 Total xylenes 0.89 Y Y - - - Y - MW5, MW19, MW24 Arsenic 0.039 - - None Barium 0.35 - - - - - None Cadmium <0.002 - - None Chromium 0.015 § - - MW5, MW13 Copper MW1, MW5, MW7, MW8, MW12, 0.0095 § - - MW13, MW19MW24, MW28, BH28, MW30, MW22, MW23 Nickel MW1, MW8, MW10, MW13, MW20, 0.44 § § § - § - MW21, MW28, BH28, MW30, MW31, MW34, Lead 0.0071 Y - - MW1, MW5, MW19, MW22,

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Beneficial use Analyte Max. Maintenance Potable water Agriculture, Stock Industrial Primary Buildings Sample locations conc. of supply - Parks and watering water use contact and exceeding Maintenance (mg/L) ecosystems acceptable gardens recreation structures of Ecosystems criteria Selenium MW1, MW8, MW10, MW12, MW13, MW20, MW24, MW28, BH28, 0.014 § § § § - § - MW32, MW34, MW17, MW22, MW23, RW1-RW5 Zinc MW1, MW5, MW7, MW8, MW10, MW12, MW13, MW20, MW21, 0.077 § - - MW24, MW28, BH28, MW30, MW31, MW32, MW33, MW34, MW17, MW22, MW23, RW2, RW3 Total Cyanide MW3, MW5, MW7, MW8, MW10, MW12, MW13, MW19, MW20, 1.9 Y Y - - - Y - MW21, MW24, BH28, MW30, MW31, MW33, MW34, MW17, MW22, MW23, RW1- RW5 Free Cyanide 0.804 Y Y - - - Y - MW5, MW7, MW28, MW32, MW33 Total PAHs 1 Y ------MW5, MW19, MW24 Benzo(a)pyren None <0.01 e - - - - - Naphthalene 1 Y ------MW5, MW19, MW24 Total Phenols 6.8 Y ------MW5, MW19, MW24 Total Cresols MW1, MW8, MW19*, MW20*, 0.04 Y ------MW17*, MW22, RW1, RW2

Ammonia as MW5, MW19, MW24, MW17, RW1, 16 N Y Y - - - Y - RW3, RW5 Nitrate 54 Y Y - Y - Y - MW12, MW13, MW28

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Beneficial use Analyte Max. Maintenance Potable water Agriculture, Stock Industrial Primary Buildings Sample locations conc. of supply - Parks and watering water use contact and exceeding Maintenance (mg/L) ecosystems acceptable gardens recreation structures of Ecosystems criteria Thiocyanate 1.3 Y - - - - - MW24 Sulphate 320 Y Y - - Y - MW13, MW28, BH28 Y Exceeds beneficial use criteria * The practical quantitation limit for these samples was above the adopted investigation level; § These analytes are considered regional impacts and/or naturally occurring; - No criteria available

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The key results of the groundwater investigations are summarised as follows:

Groundwater flow is to the north, north west towards Gardiners Creek and connectivity between the creek and groundwater appears to be seasonally affected with the creek discharging to groundwater during periods of low rainfall and groundwater discharging to the creek during periods of high flow. The interbedded materials of the site aquifer are impacted with contaminants, which are mainly comprised of cyanide, benzene, TPH and naphthalene. Metals and other organic compounds have also been identified above the maintenance of ecosystems criteria. The metals impacts, with the exception of lead, are considered to be associated with regional aquifer impacts, based on the elevated concentrations in upgradient bore MW13. The observed metals impacts, with the exception of lead are considered to be associated with regional groundwater impacts based on up-gradient bore impacts and are not considered to be site contaminants. Soil concentrations of metals were within NEPM F criteria. Free cyanide is the bioavailable form of cyanide, with total cyanide concentrations indicative of cyanide bound to organic constituents. Therefore free cyanide concentrations were considered the cyanide constituent of concern for the site. The May 2008 groundwater monitoring results reported concentrations of free cyanide,

TPH C6-C36, BTEX, PAHs, phenols and cresols metals above maintenance of ecosystems criteria.

4.5 Surface water investigations

Surface water investigations were reported as follows:

Report Surface Water Sampling Round Kilpatrick & Associates, September 2005(16) 1, 2, 3, 4, 5 (Sediment Sampling performed in March 2005) Kilpatrick & Associates, November 2005(17) 6, 7, 8, 9 Kilpatrick & Associates, March 2006(18) 10, 11, 12 Kilpatrick & Associates, June 2006(19) 13 Kilpatrick & Associates, October 2006(20) 14 Kilpatrick & Associates, July 2007(21) 15, 16, 17 Surface water sampling was also reported in the Kilpatrick & Associates, March 2003(13) and July 2004(14) reports, however the quality of those investigations were not considered suitable for the audit based on the absence of quality control and quality assurance information. Surface water quality monitoring locations are illustrated in Figure 3, Appendix A.

The key findings from sampling of Gardiners Creek are:

Creek sampling at upgradient, midgradient and downgradient locations from the site have indicated diffuse sources of impacts to the creek, particularly metals, nitrate, PAH (detected in 2008 only) and TPH. Cyanide impacts were detected above the adopted criteria and the PQL in the creek in February (Downstream 2 and Downstream 3) and March 2005 (all locations) but have

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not been detected since. The source of the cyanide impacts may have been related to the site.

4.6 Final condition of the site

The infrastructure located on the site at the date of this report is as follows:

a car park (former Gas Holder No 1) the hydraulic containment system network of recovery wells and control room a display suite a small brick building (housing Multinet gas main infrastructure) Melbourne Water sewer main and Multinet high pressure gas mains (located along the easement on the western boundary of the site) The sources of site contamination have been largely removed. A total of approximately 4,000m3 of soil was taken to landfill. These sources included underground storage tanks, waste disposal and site filling activities which resulted in contaminated fill material. Material remaining on site has been validated to NEPM F, with the exception of those locations where infrastructure or established trees prevented further excavation. Imported fill material was validated as Fill Material in accordance with EPA Bulletin 448.1(34) prior to placement on the site.

Based on the distribution of dissolved impacts, there is a possibility that further source of groundwater impacts are present in the vicinity of Gas Holder No. 1. As the base of Gas Holder No.1 is close to the groundwater table, the use of significant quantities of contaminated fill below the base during construction seems unlikely. There is also no evidence from soil analyses that significant impacts are present below the gasholder floor. Fill placed around the outside of the gas holder walls following construction may be a source of groundwater impacts. It is noted that further potential source impacts remain in the fill material within the services easement along Gardiners Creek.

Material remaining on-site and exceeding NEPM F criteria are detailed in Table 4-4 below and illustrated in Figure 5, Appendix A. Residual benzene and cyanide groundwater impacts are presented in Figure 6.

Table 4-4: Site locations exceeding NEPM F criteria

Location Depth Contaminant(s) Comment (mBGL) mg/kg Residual material adjacent to infrastructure at the time of excavation BH57 NW-2 0.5 PAH at 120 Further excavation precluded by the mg/kg, B(a)P at presence of trees, the perimeter 7.74 mg/kg fence and a monitoring well BH58 SW-3 0.5 PAH at 110mg/kg, Further excavation precluded by B(a)P at trees and the perimeter fence 8.02mg/kg BH58 B/0.8-2 0.8 to 2 PAH at 120mg/kg, A gas main prevented further B(a)P at excavation 9.07mg/kg

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Location Depth Contaminant(s) Comment (mBGL) mg/kg Residual material adjacent to infrastructure at the time of excavation BH70 WW-2 0.5 PAH at 620mg/kg, The north eastern entrance gate and B(a)P at driveway prevented further 42.6mg/kg excavation BH28 0.5 PAH at 218mg/kg, the presence of a groundwater well B(a)P at 23mg/kg location prevented further excavation, but material at this location was largely removed Material at depth BH80 - Base of Gas 3.65 Pb at 1200mg/kg The impacts noted in this material Holder No. 2. mBGL and PAH at are semi-volatile, and at this depth 140mg/kg are not considered to impact upon potential beneficial uses of the land. Groundwater impacts in this area are below the adopted criteria for PAH, benzo(a)pyrene and lead indicating a lack of groundwater impacts from the overlying soil. Fill material Services easements Not Likely to be PAHs The presence of services the fill along the western sampled and metals material could not be assessed. boundary of the site. Based on impacts in fill across the site, this material is likely to be variously impacted with site contaminants.

With the sources of contamination largely removed from the site, the Auditor considers that the site soil has been remediated to the extent practicable.

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5. Quality of available data

The quality of the available data relating to the site was assessed as follows:

The available site investigation and remediation reports(6-22) have been audited against documents referenced by the EPA(1,5) and other relevant standards and guidelines(23-32,34, 38,39) in order to verify the quality and completeness of the assessment.

The Auditor or his representative attended the site on numerous occasions, the latest in October 2007 to gain an appreciation of the conditions and remedial works conducted at the site.

All the assessors’ quality assurance/quality control (QA/QC) data acquired from the field samples collected and analysed were also audited.

The results of these quality assessments are discussed below.

5.1 Review of environmental site assessment data

The following environmental reports were reviewed for this audit:

CMPS&F, Department of Treasury and Finance, Site Investigation, Tooronga Depot, Kaikoura Avenue, Tooronga, Victoria. October 1997.(6)

GSB Land Remediation Division, Multinet, Soil Contamination Assessment of Proposed Parking Areas, No. 16 Kaikoura Avenue, Tooronga. January 1998. (7)

Egis Consulting, United Energy, Tooronga Office Site Victoria, Environmental Site Assessment Report. September 1999. (8)

Egis Consulting, Australand Holdings 742 Toorak Road, Hawthorn East Supplementary Environmental Site Assessment Report. February 2001. (9)

VEMCO Environmental Services, Site History Appraisal & Assessment Summary, 742 Toorak Road, Hawthorn East. October 2001. (10)

Kilpatrick & Associates Pty Ltd, Environmental Status Report - 742 Toorak Road, Hawthorn East. May 2002. (11)

Kilpatrick & Associates Pty Ltd, Environmental Site Assessment, 742 Toorak Road, Hawthorn East (Arcadia Grove). March 2003. (12)

Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). December 2003. (13)

Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). July 2004. (14)

Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East - Groundwater Status Report. August 2004. (15)

Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). September 2005. (16)

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Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). November 2005. (17)

Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). March 2006. (18)

Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). June 2006. (19)

Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). October 2006. (20)

Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). July 2007. (21)

Bureau Veritas HSE Pty Ltd, Environmental Audit, Summary of Works August 2007 – May 2008, 742 Toorak Road, Hawthorn East, VIC. June 2008. (22)

Details of site history reviews undertaken are detailed in Table 5-1 below. Although consideration has been given to all previous assessment reports, the following reports were considered of low significance due to the limited nature and lack of quality control for the investigations contained therein:

CMPS&F, Department of Treasury and Finance, Site Investigation, Tooronga Depot, Kaikoura Avenue, Tooronga, Victoria. October 1997.(6)

GSB Land Remediation Division, Multinet, Soil Contamination Assessment of Proposed Parking Areas, No. 16 Kaikoura Avenue, Tooronga. January 1998. (7)

VEMCO Environmental Services, Site History Appraisal & Assessment Summary, 742 Toorak Road, Hawthorn East. October 2001. (10)

The CMPS&F, GSB Land Remediation Division and VEMCO reports were considered for the history review, but the soil and/or groundwater investigations were not considered sufficient for the audit with respect to quality and are therefore not considered in the soil and groundwater investigation sections.

5.2 Site history review

While there are minor gaps in the information as presented in the historic reports, the auditor considers that the site history review is adequate for the purpose of this audit. The scope and findings of the auditors review are detailed in Table 5-1 below.

Table 5-1: Quality of site history reviews

Objective Comments Report Title plan/clear No. The site is shown on site plans excluding (Kilpatrick & Associates, description of Audit Lot 1 on PS406054P, however site plans in the December 2003) (13) site Kilpatrick & Associates reports show the site without this lot on the north west corner of the site. The Auditor has clarified the Audit area boundaries, which have been clearly indicated on Figure 6, Appendix A. Certificates of title are provided in Appendix C.

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Objective Comments Report Zone planning The report identifies current zoning as (Kilpatrick & Associates, information provided commercial/industrial without providing the December 2003) (13) Council Zoning Plan. Other reports also erroneously identify the site as zoned industrial. The Auditor has performed a review of the Boroondara Planning Scheme and found that the site is zoned PUZ1 – Public Use Zone Service and Utility. Beneficial uses to be Kilpatrick & Associates identified protected (Kilpatrick & Associates, protected identified beneficial uses based on the residential December 2003: development of the site. The current site Sections 1.5, 6.4 and development plans are for a commercial 7.4) (13) development. The beneficial uses are detailed in Section 2.5. Historic uses of Yes. Storage of manufactured gas; gas (Kilpatrick & Associates, audit site company depot and vehicle maintenance centre December 2003: including underground storage tanks; office Appendix 3) (13) space. Historic uses offsite Yes. Refer to section 2.2. (Kilpatrick & Associates, December 2003: Appendix 3) (13) Aerial photographs Yes. (Kilpatrick & Associates, inspected December 2003: Appendix 3) (13) Geological survey Yes. Refer to section 2.1. (Kilpatrick & Associates, maps inspected December 2003: Section 2.2) (13) Groundwater Yes. Refer to section 2.4. (Kilpatrick & Associates, database inspected December 2003: Appendix 6) (13) Site inspected and A site inspection was performed in March 2002. (Kilpatrick & Associates, description provided A description of the site was provided. December 2003: Section 3) (13) Site interviews No references to site interviews contained in the conducted reports. Description of Yes. (Kilpatrick & Associates, current and December 2003: historical structures Appendix 6) (13) Potentially Yes. Refer to section 2.1. (Kilpatrick & Associates, contaminating uses December 2003: identified Section 6.1) (13)

5.3 Soil investigations

Details of the quality of soil investigations including quality control undertaken at the site are detailed in Table 5.2 below.

Table 5-2: Quality of soil investigation works

Objective Comments Report Sampling frequency 20 Sample locations Egis Consulting, September 1999; Section 3. (8) 14 Sample locations Egis Consulting,

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Objective Comments Report February 2001: Section 4. (9) 56 Sample locations Kilpatrick & Associates, May 2002(11) Refers to soil sampling performed in 2002 Kilpatrick & (Kilpatrick, 2002) and Egis Consulting’s previous Associates, March investigation works. Additional soil investigations 2003 and Kilpatrick were performed at 27 sample locations. & Associates, December 2003 (amendments) (12,13) Soil excavation at hot spots and validation sampling. Kilpatrick & Sampling frequency based on size of excavation and Associates, considered appropriate. September 2005(16) OVERALL AUDIT SUMMARY – The total sampling frequency is considered adequate to assist in the audit determination of the site. Sampling pattern Targeted / grid sample locations Egis Consulting, September 1999; Section 3; Figure 1. (6) Grid sample locations (locations placed to infill the Egis Consulting, previous sampling points advanced by Egis in 1999). February 2001; Section 4. (9) Targeted / grid sample locations. The number of Kilpatrick & samples exceeded AS4482.1 requirements for grid- Associates, May based sampling of hot spots. 2002(11) Refers to soil sampling performed in 2002 Kilpatrick & (Kilpatrick, 2002) and Egis Consulting’s previous Associates, March investigation works. Targeted locations based on the 2003 and Kilpatrick Kilpatrick May 2002 investigations. & Associates, December 2003 (amendments) (12,13) OVERALL AUDIT SUMMARY – The overall sampling pattern is considered adequate to assist in the audit determination of the site. Point sources The investigation targeted the following areas: fuel Egis Consulting, targeted tank area; south eastern garden beds and parking September 1999; areas; eastern grassed lot; north eastern garden Section 3; Figure 1. beds; western storage and parking areas; south (6) western underground car park area. The testing undertaken was considered limited due to the absence of sampling within the building footprint and one of the three gas holders. Point sources were not targeted. The sampling Egis Consulting, program was based on infilling of areas not February 2001; previously sampled. Section 4. (9) Targeted areas previously identified as impacted by Kilpatrick & Egis Consulting, 2001. Associates, May 2002(11) Refers to soil sampling performed in 2002 Kilpatrick & (Kilpatrick, 2002) and Egis Consulting’s previous Associates, March investigation works. Point sources identified during 2003 and Kilpatrick the Kilpatrick May 2002 assessment were targeted. & Associates, December 2003

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Objective Comments Report (amendments) (12,13) OVERALL AUDIT SUMMARY – The point sources are considered to have been adequately targeted to assist in the audit determination of the site. Sampling method Samples were collected from solid stem and hollow Egis Consulting, flight augers. The sampling pattern and extent of September 1999; sampling was considered inadequate to address all Section 3.1(8) potential sources of contamination on site. The sampling method included composite sampling, which was considered unacceptable for the purposes of the Audit. Egis’s field procedures are considered to be acceptable. Soil samples were collected in general accordance with AS 4482.1 – 2005 Samples were collected from solid flight augers. The Egis Consulting, sampling pattern and extent of sampling was February 2001; considered inadequate to address all potential Section 5. (9) sources of contamination on site. However the number of samples in the 2001 investigation plus the 1999 investigation were sufficient to satisfy AS4482.1 minimum sampling points required Sampling method was by solid flight auger or hand Kilpatrick & auger. The methods were satisfactory for the Associates, May purposes of the audit. 2002(11) Sampling methods included split spoon augers, Kilpatrick & hand augers and sampling from excavator buckets. Associates, March The methods were satisfactory for the purposes of 2003 and Kilpatrick the audit. & Associates, December 2003 (amendments) (12,13) OVERALL AUDIT SUMMARY – The sampling methods are considered adequate to assist in the audit determination of the site. Depth of samples Soil samples were analysed from depths of between Egis Consulting, 0.1mBGL to 0.5mBGL. Boreholes were advanced to September 1999; a maximum depth of 2mBGL in 19 of the 20 Section 3 and 4(8) locations and to 6mBGL at one location. Soil descriptions and borehole logs are included in the ESA report. The depth of the samples analysed and the absence of fill material delineation was not considered acceptable. Soil bores were advanced to depths of up to 6mBGL. Egis Consulting, Soil samples were analysed from depths of between February 2001; 0.1mBGL and 1.5mBGL. The depth of the samples Appendix B. (9) analysed and the absence of fill material delineation was not considered acceptable. Soil bores were advanced to depths of between Kilpatrick & 0.25mBGL and 10.1mBGL. The depth of samples Associates, May analysed and delineation of fill material was 2002(11) considered adequate. Samples were collected from depths of between Kilpatrick & 0.05mBGL and 8.0mBGL. The depth of sampling Associates, March was considered acceptable. 2003 and Kilpatrick & Associates, December 2003 (amendments) (12,13)

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Objective Comments Report OVERALL AUDIT SUMMARY – The overall depth of sampling is considered adequate to assess the depth of soil impacts including fill material at the site. Contaminants Soil: Chlorinated hydrocarbons, TPH, BTEX, PCBs, Egis Consulting, analysed consistent OCPs, OPPs, PAHs, Phenols, Cresols, Metals September 1999; with history (antimony, arsenic, beryllium, cadmium, chromium, Appendix G. (8) cobalt, copper, lead, mercury, molybdenum, nickel, selenium tin, zinc), Phenols, Cyanide, sulphate, sulphide, pH and Ammonia. The analytes tested for were considered to adequately address potential issues identified from the site history review. Soil: PAHs, Metals (antimony, arsenic, beryllium, Egis Consulting, cadmium, chromium, cobalt, copper, lead, February 2001; manganese, mercury, molybdenum, nickel, Appendix D(9) selenium, tin, zinc), The analytes tested for were not considered to adequately address potential issues identified from the site history review. Soil: Metals (antimony, arsenic, barium, beryllium, Kilpatrick & boron, cadmium, chromium, cobalt, copper, lead, Associates, May mercury, molybdenum, nickel, selenium, tin, 2002(11) vanadium, zinc), cyanide, fluoride, sulphate, pH, TPH, MAH, total phenolics, PAHs, OCPs, PCBs, halogenated volatile organics, cresols and phenols. The analytes tested for were considered to adequately address potential issues identified from the site history review. Soil samples were variously analysed for TPH, Kilpatrick & BTEX, PAH, metals (antimony, arsenic, barium, Associates, March beryllium, boron, cadmium, chromium, cobalt, 2003 and Kilpatrick copper, lead, mercury, molybdenum, nickel, & Associates, selenium, tin, vanadium, zinc) and phenols. The December 2003 analytes were considered appropriate for the (amendments) (12,13) targeted locations. OVERALL AUDIT SUMMARY – The contaminants analysed are considered adequate to address potential issues identified from the site history review. Asbestos Asbestos was reported in two borehole logs at Egis Consulting, considered depths between 1.0 and 1.5mBGLin the eastern and September 1999; north eastern parking areas; Appendix D. (8) No reference to consideration of asbestos on site Egis Consulting, could be located within the ESA document. February 2001(9) Reference is made to the previous identification of Kilpatrick & Asbestos by Egis, 2001. No further reference to Associates, May consideration of asbestos on site could be located 2002(11) within the document. Reference is made to the previous identification of Kilpatrick & Asbestos by Egis, 2001. No asbestos was reported Associates, March in bore logs prepared for the site. 2003 and Kilpatrick & Associates, December 2003 (amendments) (12,13)

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Objective Comments Report OVERALL AUDIT SUMMARY – Minor asbestos debris was observed in early investigation works. Subsequent works have not identified any asbestos material and no asbestos was observed during the Auditor’s site walkover. Asbestos is not considered a concern for the site. Has soil Various stages of assessment were performed at the Egis Consulting, contamination been site and contamination was excavated to the extent September 1999(8); delineated vertically practicable both vertically and horizontally within the Egis Consulting, and horizontally various former infrastructure pits (USTs, hoists, pits) February 2001(9); and art other locations where hot spots were Kilpatrick & identified. The overall extent of contamination was Associates, May delineated horizontally and vertically across the site 2002(11); Kilpatrick and is considered adequate for the purposes of the & Associates, audit. March 2003 and Kilpatrick & Associates, December 2003 (amendments) (12,13); Kilpatrick & Associates, September 2005(16)

QA/QC Samples AS4482.1 recommends 1 blind duplicate and 1 split duplicate per 20 primary samples. And 1 rinsate blank per day per matrix per piece of equipment. Egis Consulting, September 1999(8) Intra-laboratory 1 intra-laboratory duplicate was taken for 22 Appendices H and I duplicates samples.

Inter-laboratory The number of inter-laboratory duplicates was 1 for duplicates 22 samples. Rinsate blanks One rinsate blanks was collected as part of the Appendix I project QA. Trip blanks Trip blanks were not collected during the sampling. Background Three locations (BH6, BH7, BH8) were sampled at samples an adjacent residential property that was part of the original site. These samples might be considered background samples. Relative percent One analyte (Chromium) exceeded the accepted Appendix I Table 9 difference (RPD) RPD range. The exceedence was likely due to soil and 10 heterogeneity and low concentrations of analytes. The exceedence is not considered to affect the results of the assessment. Analytical methods Laboratory certificates showed NATA endorsement Appendices F and J NATA endorsed for the analytical methods used. Chain of Custody Relevant CoCs were provided and the samples were Appendix E (CoC) noted to have been analysed within the appropriate documentation & holding times. holding times Adequacy of QA/QC The QA/QC data from the assessments were Section 4.2.5 generally considered to be satisfactory. Transcription of No issues were noted that would materially impact Data by Assessor upon the conclusions of the report.

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Objective Comments Report Assessment The conclusions of the assessment reports were Conclusions considered acceptable in relation to the condition of soils. Egis Consulting, February 2001(9) Intra-laboratory 2 blind duplicates were taken for 29 samples. Appendix D and E duplicates There were no issues with the results of the duplicate samples.

Inter-laboratory Only 1 inter-laboratory sample was taken for 29 Table 2 Appendix E duplicates samples.

Rinsate blanks Rinsate blanks were not collected during the sampling. Trip blanks Trip blanks were not collected during the sampling. Background One background sample location (BH29) was samples sampled at an adjacent residential property that was part of the original site. Relative percent Two analytes (Benzo(k)Fluoranthene and Indeno Appendix E difference (RPD) (1,2,3,-cd) Pyrene) exceeded the accepted RPD range. The difference in analyte concentrations was likely due to the heterogeneity of the fill material from which the sample was taken. Analytical methods Laboratory certificates showed NATA endorsement Appendix D NATA endorsed for the analytical methods used. Chain of Custody Relevant CoCs were provided and the samples were Appendix C (CoC) noted to have been analysed within the appropriate documentation & holding times. One of the CoC documents was holding times missing a receiving signature. Adequacy of QA/QC The QA/QC data from the assessments were generally considered to be satisfactory. Transcription of No issues were noted that would materially impact Data by Assessor upon the conclusions of the report. Assessment The conclusions of the assessment report were Conclusions considered acceptable in relation to the condition of soil. Kilpatrick & Associates, May 2002(11) Intra-laboratory 6 intra-laboratory duplicates were taken for 118 Attachment VII duplicates samples.

Inter-laboratory 7 inter-laboratory samples were taken for analysis. Attachment VII duplicates

Rinsate blanks 6 Rinsate blanks were collected and 3 analysed for metals. The results reported concentrations below Attachment V the laboratory quantitation limits. Trip blanks Trip blanks were not collected during the sampling Background Background samples were not collected during this samples project. Relative percent A large number of RPD results were outside the Table 8 Attachment difference (RPD) allowable 50% tolerance. This is potentially due to VI difference in laboratory reporting limits, or the heterogeneity of the fill material sampled. Analytical methods Laboratory certificates showed NATA endorsement Attachment VII NATA endorsed for the analytical methods used.

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Objective Comments Report Chain of Custody Relevant CoCs were provided and the samples were Attached to existing (CoC) noted to have been analysed within the appropriate QA material documentation & holding times. One ‘Analysis Request form’ not holding times signed when relinquished Adequacy of QA/QC The QA/QC data from the assessments were generally considered to be satisfactory. Transcription of No issues were noted that would materially impact Attachments V and Data by Assessor upon the conclusions of the report. VI Assessment The conclusions of the assessment report were Conclusions considered acceptable in relation to the condition of soil. Kilpatrick & Associates Pty Ltd, Environmental Site Assessment, 742 Toorak Road, Hawthorn East (Arcadia Grove). March 2003. (12) Intra-laboratory Five intra-laboratory duplicates were taken for 118 Appendix XX Table duplicates primary samples. 13 and 14 Inter-laboratory Five inter-laboratory samples were taken for 118 Appendix XX Table duplicates primary samples. 13 and 14 Rinsate blanks Rinsate blanks were collected during the sampling. Appendix XX Table All of the samples were below laboratory detection 13 and 14 limits (<0.005 or <0.001). Trip blanks Trip blanks were not collected during the sampling Background Background samples were not collected during this samples project. Relative percent Majority of RPDs for the inter- and intra-laboratory Appendix XX Table difference (RPD) samples were >50%. This was potentially due to the 13 and 14 heterogeneity of the fill, low analyte concentrations and different laboratory detection limits. Analytical methods Laboratory certificates showed NATA endorsement Appendix XVII NATA endorsed for the analytical methods used. Chain of Custody Relevant CoCs were provided and the samples were Appendix XI (CoC) noted to have been analysed within the appropriate documentation & holding times. One ‘Analysis Request form’ was not holding times signed when relinquished and one not signed when received. One Request for additional Analysis form was not signed. Adequacy of QA/QC Although deficiencies in the QA/QC were identified, these were not expected to materially affect the results of the assessment. Transcription of No issues were noted that would materially impact Data by Assessor upon the conclusions of the report. Assessment The conclusions of the assessment report were Conclusions considered acceptable in relation to the condition of soil.

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Objective Comments Report Kilpatrick & Associates Pty Ltd, September 2005. (16) Intra-laboratory Nine intra-laboratory duplicates were taken for 96 Table 10, duplicates primary samples. Laboratory Reports Inter-laboratory Ten inter-laboratory duplicates were taken for 96 duplicates primary samples.

Rinsate blanks Rinsate blanks were not required during soil validation works. Samples were taken with a disposable glove directly from the surface of excavations. Trip blanks Four trip blanks were collected during the seven Table 10, days of validation sampling. All results were below Laboratory Reports the laboratory quantitation limits. Background Background samples were not collected during soil samples validation and were not required. Relative percent Both the RPDs for the Blind and Split duplicates Table 10, Report difference (RPD) were exceeded in over 80% of the duplicate samples body (inter and intra-laboratory). Due to the heterogeneity of the impacted soil, the large RPD differences are considered acceptable. Analytical methods Laboratory certificates showed NATA endorsement Laboratory Reports NATA endorsed for the analytical methods used. Chain of Custody Relevant CoCs were provided and the samples were Laboratory Reports (CoC) analysed within the appropriate holding times. documentation & holding times Adequacy of QA/QC The QA/QC data from the assessments were generally considered to be adequate. Transcription of No issues were noted that would materially impact Data by Assessor upon the conclusions of the report. Assessment The conclusions of the assessment report were Conclusions considered acceptable in relation to the condition of soil. OVERALL AUDIT SUMMARY OF QA/QC – The quality control data in the various assessment reports varied. During all assessments, sufficient blind and split duplicate samples were taken and RPDs were considered acceptable. Rinsate blanks and field blanks were not collected during each sampling round. The overall number of blank samples was considered acceptable to give an indication of the quality of the sampling program. The omission of blank samples was not considered to affect the conclusions of this audit. Based on the above, although there were unsatisfactory areas of QA/QC practice, the Auditor considered that overall, the available soil data were of a suitable quality and completeness to support the enclosed Statement of Environmental Audit.

5.4 Groundwater investigations

Details of the quality of groundwater investigations including quality control undertaken are detailed in Table 5-3 below.

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Table 5-3: Quality of groundwater investigation works

Objective Comments Report Point sources Three groundwater monitor wells were installed on the Egis Consulting, targeted site (BH28, BH29, BH30) to depths of between 5 and February 2001: 6mBGL. Bores were positioned in a triangular pattern Section 5.1. (9) on the east, west and southern boundary areas of the site. BH29 was positioned off-site to the east. Point sources were not targeted, however BH28 was located down hydraulic gradient from Gas Holder No. 1. One round of groundwater monitoring was performed. The groundwater investigation was considered insufficient to characterise the groundwater condition at the site. Five groundwater monitoring wells were installed Kilpatrick & (MW1-MW5) at the site into the upper aquifer to a Associates, May depth of approximately 7mBGL. One monitoring well 2002(11) (MW2) was dry. The locations included one target bore (MW5) within former Gas Holder No. 1. The other bores were located on the south, east and west boundaries of the site. Sampling performed April 2002. Twenty-two groundwater monitoring bores were Kilpatrick & proposed to be installed at the site (MW6- MW27), Associates, March however one of these was prematurely demolished 2003 and and three proposed bores were never installed (MW9, Kilpatrick & MW14, MW15). A total of eighteen bores were Associates, installed at the site and sampled. The bores targeted December 2003 each of the former gas holders. The number of bores (amendments) was considered sufficient to characterise site sources. (12,13) Sampling of all bores was performed in June and November 2002, March and May 2003. Four groundwater monitoring wells installed off-site to Kilpatrick & the north, north east and north west (MW28-MW31). Associates, July The bores were positioned down hydraulic gradient 2004(14) from the site to target potential off-site impacts. Sampling performed for all site bores - March 2004. Groundwater monitoring events targeting various Kilpatrick & bores across the site including bores within and Associates, around former Gas Holder No. 1, which is considered September the main source of site impacts. 2005(16); Kilpatrick & Associates, November 2005(17); Kilpatrick & Associates, March 2006(18); Kilpatrick & Associates, July 2007(21) Five recovery wells (RW1-RW5) were installed as part Bureau Veritas of the hydraulic containment system along the western 2008(22) boundary of the site along the path of groundwater migration to Gardiners Creek. Groundwater monitoring was performed at monitoring bores MW1, MW3, MW5, MW7, MW8, MW10, MW12, MW13, MW19, MW21, MW24, MW28, BH28, MW30-MW34, MW17, MW22, MW23, RW1-RW5. The bores installed along the western boundary (site recovery bores and MW30-MW34) targeted downgradient impacts from the former gas holders.

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Objective Comments Report OVERALL AUDIT SUMMARY – The groundwater monitoring bores at the site were considered to be sufficient to target point sources, namely gas holder and former workshop infrastructure impacts. Well screening Wells were screened between 2-5mBGL and 3- Egis Consulting, 6mBGL. It was considered that the depth of the well February 2001: screens may have been insufficient to fully Section 5.1. (9) characterise the upper aquifer. However the bores were considered suitable for the collected of analytical data. Wells were screened in between 0.75mGBL and Kilpatrick & 2.3mBGL (MW5 within former Gas Holder No. 1, and Associates, May MW2 (location not provided)) and 3mBGL to 9mBGL. 2002(11) The depth of the screens was considered appropriate.

Bores were screened within the upper and lower Kilpatrick & aquifers at the site. The upper aquifer screened Associates, March interval was generally between 3.5mBGL and 2003 and 8.5mBGL. The lower aquifer was generally screened Kilpatrick & between 8mBGL to 14mBGL. The depth of the Associates, screens was considered appropriate. December 2003 (amendments) (12,13) Wells were screened in the upper aquifer at depths of Kilpatrick & between 3.5mBGL and 11.5mBGL. The screened Associates, July interval was considered appropriate. 2004(14) Monitoring bores MW10(replacement), Bureau Veritas MW20(replacement), MW32-MW34, RW1-RW5 2008(22) screened between 4 and 12 mBGL. Monitoring Bores MW32 - MW34 were constructed for monitoring of the hydraulic containments system and RW1 – RW5 were constructed as pumping wells for hydraulic containment system. These bores were screened between 4 and 12 mBGL. The screened interval was considered appropriate. OVERALL AUDIT SUMMARY – The well screens were considered of appropriate depth and interval to assess the upper aquifer. Sampling method The groundwater bores were purged dry with a Egis Consulting, waterra foot valve system and sampled upon February 2001: recharge. Groundwater parameters were monitored Section 5.1. (9) during purging (pH, DO, EC and temperature) and recorded. The sampling method was not considered acceptable for volatile analytes. Sampling methods were reported to be in accordance Kilpatrick & with AS5667.11:1998 and the ANZECC Guidelines Associates, May (1992). Details of the sampling methods were not 2002(11) provided. The lack of sampling method details was considered unacceptable.

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Objective Comments Report Sampling was performed by micropurge and the Kilpatrick & methods used were considered acceptable for the Associates, March purposes of the audit. 2003 and Kilpatrick & Associates, December 2003 (amendments) (12,13) Bores were sampled using bailers or micropurge Kilpatrick & equipment. Bailers were used where recharge was Associates, July low. Although the use of bailers is not generally 2004(14) considered acceptable for volatile sampling, based on the low recharge of the bores the methods used were considered acceptable. Bores were sampled using bailers or micropurge Kilpatrick & equipment. Although the use of bailers is not generally Associates, considered acceptable for volatile sampling, based on September the low recharge of the bores the methods used were 2005(16); Kilpatrick considered acceptable. & Associates, November 2005(17); Kilpatrick & Associates, March 2006(18); Kilpatrick & Associates, July 2007(21) Low flow micro-purge technique was used to sample Bureau Veritas all monitoring wells. Recovery bores (RW1-RW5) 2008(22) were sampled from in-situ pumping equipment after purging from designated water discharge points. OVERALL AUDIT SUMMARY – Although the Egis 2001 sampling methods were not suitable for the contaminants of concern, the subsequent investigations used appropriate techniques for groundwater sampling and are considered suitable for the audit. Purge field Wells were purged until field parameters stabilised, Egis Consulting, parameters apart from well BH30, for which only one set of February 2001: parameters was recorded. Section 5.1. (9) Purge parameter details were not provided. Kilpatrick & Associates, May 2002(11) Wells were purged until field parameters stabilised. Kilpatrick & The approach was considered acceptable. Associates, March 2003 and Kilpatrick & Associates, December 2003 (amendments) (12,13) Wells were purged until field parameters stabilised. Kilpatrick & Field parameters not taken in wells with low recharge Associates, July (MW19, MW24, MW25, MW27). The approach was 2004(14) considered acceptable. Wells were purged until field parameters stabilised. Kilpatrick & Associates, September 2005(16); Kilpatrick

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Objective Comments Report & Associates, November 2005(17); Kilpatrick & Associates, March 2006(18); Kilpatrick & Associates, July 2007(21) Wells were purged until groundwater parameters had Bureau Veritas, stabilised. Recovery wells (RW1-RW5) were purged 2008(22) for approximately 10 minutes (flow from the discharge point). The approach was considered acceptable. OVERALL AUDIT SUMMARY – Purge field parameters were provided in all but one report and the stabilisation of groundwater parameters were in overall compliance with EPA guidelines. Although some details were not provided as noted above, overall the groundwater purge field parameters were considered suitable for the purposes of the audit. Groundwater Flow Inferred groundwater flow direction was toward the Egis Consulting, Direction/Elevation west. However monitoring wells were not surveyed so February 2001: the direction of flow could not be definitively identified. Section 5.1. (9) Groundwater contour plans were provided and Kilpatrick & indicated flow towards Gardiners Creek to the north, Associates, May north west. A groundwater sink was noted within the 2002(11) former Gas Holder No. 1 at MW5 (which may be related to operation of the sump within the car park). The report indicated that more permeable sediments may be located beneath the gas holder. It is noted that historically a sump pump operated within the former Gas Holder to prevent basement flooding. Groundwater contour plans were provided and Kilpatrick & indicated flow in the upper aquifer towards Gardiners Associates, March Creek to the west, north west. A sink was present 2003 and within former Gas Holder No. 1. Some recharge was Kilpatrick & also observed at former Gas Holder No. 2. Flow in the Associates, lower aquifer was to the north, north west, towards December 2003 Gardiners Creek. The lower aquifer appeared less (amendments) controlled by sub-surface structures (former gas (12,13) holders) due to the lack of mounds or sinks. Groundwater contour plans were provided and showed Kilpatrick & flow to the west, north west towards Gardiners Creek. Associates, July Bores installed to the west of Gardiners Creek also 2004(14) showed flow towards the creek. Groundwater contour plans showed flows similar to Kilpatrick & previous gauging round. Associates, September 2005(16); Kilpatrick & Associates, November 2005(17); Kilpatrick & Associates, March 2006(18); Kilpatrick & Associates, July 2007(21), Bureau Veritas 2008. (22)

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Objective Comments Report OVERALL AUDIT SUMMARY – Groundwater elevation contour plans were considered acceptable to determine the overall flow direction of groundwater at the site and interaction with the adjacent creek. Contaminants The analytes tested for included metals, OCP, TPH, Egis Consulting, analysed consistent PAH, phenols, cresols, chlorinated hydrocarbons, February 2001: with operations, BTEX and cyanide, and were considered to Section 5.1. (9) history or EPA adequately address potential issues associated with screen the previous site use. Analytes were metals, TPH, BTEX, PAH and phenols. Kilpatrick & Although the analytes were not comprehensive, the Associates, May suite provided an indication of potential site issues 2002(11) and subsequent investigations would address gaps in the analytical program. The analytes tested for included: arsenic, barium, Kilpatrick & beryllium, cadmium, chromium, cobalt, copper, Associates, March mercury, lead, manganese, molybdenum, nickel, 2003 and selenium, tin, vanadium , zinc, OCP, TPH, PAH, PCB, Kilpatrick & phenols, cresols, chlorinated hydrocarbons, BTEX and Associates, cyanide (total), thiocyanate, fluoride and sulphate. The December 2003 chosen analytes were considered to adequately (amendments) address potential issues associated with the previous (12,13) site use. The analytes tested for included: arsenic, beryllium, Kilpatrick & cadmium, chromium, cobalt, copper, mercury, lead, Associates, July molybdenum, nickel, selenium, tin, vanadium , zinc, 2004(14) OCP, TPH, PAH, phenols, chlorinated hydrocarbons, BTEX and cyanide (free and total), thiocyanate, fluoride, nitrate, ammonia, and sulphate. The selected analytes were considered to adequately address potential issues associated with the previous site use. The analytes tested for included: metals (as previous Kilpatrick & 2004 rounds), TPH, PAH, phenols, cresols, BTEX and Associates, cyanide (total and free), thiocyanate, pH, TDS, and September sulphate. The selected analytes were considered to 2005(16) adequately address potential issues associated with the previous site use. The analytes tested for included: metals (as previous Kilpatrick & 2004 rounds), TPH, PAH, phenols, cresols, BTEX and Associates, cyanide (total and free), thiocyanate, ammonia and November 2005(17) nitrate. The selected analytes were considered to adequately address potential issues associated with the previous site use. The analytes tested for included: metals (as previous Kilpatrick & 2004 rounds), TPH, PAH, phenols, cresols, BTEX and Associates, March cyanide (total and free), thiocyanate, TDS, ammonia 2006(18) and nitrate. The selected analytes were considered to adequately address potential issues associated with the previous site use. The analytes tested for included: metals (as previous Kilpatrick & 2004 rounds), TPH, PAH, phenols, cresols, BTEX and Associates, July cyanide (total and free), thiocyanate, TDS, pH, 2007(21) ammonia and nitrate. The selected analytes were considered to adequately address potential issues associated with the previous site use. It is noted that analysis of TPH, PAH and mercury for most samples was omitted due to laboratory error. Subsequent rounds included these analytes.

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Objective Comments Report The analytes tested for included those noted above Bureau Veritas (July 2007) and TPH, PAH and mercury. It is noted 2008(22) that during the February 2008 round MW16 (PSH present, and presumed to be from adjacent service station) and MW20 (well damaged) were not sampled. Also during the May 2008 sampling round MW16 was not sampled due to PSH, presumed to be from the adjacent service station (based on product identification analysis). OVERALL AUDIT SUMMARY – The analytes tested for were considered to adequately address potential contamination issues associated with the previous site uses (former gas storage facility, and vehicle maintenance areas including underground storage tanks) and introduction of fill material for site levelling and construction. Background BH29 located off-site to the east on a residential lot Egis Consulting, samples may be considered a background bore for the site. February 2001: However the bore may not have fully intersected the Section 5.1. (9) aquifer. Based on the preliminary nature of the investigation, the lack of complete intersection of the aquifer was not considered to affect the audit. Subsequent investigations included further background wells. No background samples were obtained during this Kilpatrick & phase of works. Associates, May 2002(11) Background samples were obtained from off-site bore Kilpatrick & MW13. Background well MW28 was sampled in Associates, March March 2004 (Round 6), February 2008 (Round 11) 2003 and and May 2008 (Round 12). Kilpatrick & Associates, December 2003 (amendments) (12,13); Kilpatrick & Associates, July 2004(14); Kilpatrick & Associates, September 2005(16); Kilpatrick & Associates, November 2005(173); Kilpatrick & Associates, March 2006(18); Kilpatrick & Associates, July 2007(21) OVERALL AUDIT SUMMARY – The investigations from 2003 onwards included a background monitoring well sampled for the contaminants of concern. Monitoring wells MW13 and MW28 were the background wells and are located off-site and up hydraulic gradient from the audit site and are indicative of background conditions. Elevated metals concentrations were reported in the background wells. Elevated Cr, Cu, Ni, Se, Zn concentrations above the SEPP Waters of the Yarra River and tributaries (Schedule F7) criteria were reported during the 2008 monitoring events. Previous monitoring events also

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Objective Comments Report reported elevated concentrations of B, Hg, Mn and Mo. Nitrate and sulphate were above the ANZECC 2000 Fresh Water Ecosystem Protection 95% Protection Level. Has groundwater Groundwater impacts across the site were considered Bureau Veritas contamination been to have been delineated horizontally and vertically. 2008(22) delineated vertically and horizontally OVERALL AUDIT SUMMARY – The dissolved hydrocarbon and cyanide impacts have been identified at various bore locations across the site over time. The bulk of the impacts for free cyanide and benzene are beneath or adjacent to the underground car park (former Gas Holder No. 1.). Off-site impacts are constrained by the presence of the Gardiners Creek which is connected to groundwater and is the discharge point for groundwater impacts. Monitoring of the creek has therefore been required to determine the horizontal extent of impacts and delineation in groundwater is limited by the presence of the creek. Product identified in off-site bore MW16 is considered to be from the adjacent service station based on the petroleum hydrocarbon fingerprint; proximity to the service station; and absence of phase separated hydrocarbon identified on the site.

QA/QC Samples AS4482.1 recommends 1 blind duplicate and 1 split duplicate per 20 primary samples. And 1 rinsate blank per day per matrix per piece of equipment. Egis Consulting, February 2001: Section 5.1. (9) Intra-laboratory 1 intra-laboratory duplicate was taken for 3 samples. Appendix G duplicates

Inter-laboratory No inter-laboratory duplicates were collected during duplicates the sampling. Rinsate blanks No Rinsate blanks were collected during sampling. Trip blanks Trip blanks were not collected during the sampling Background Background samples were not collected. samples Relative percent RPD for the intra-laboratory blind duplicate was Appendix H difference (RPD) acceptable for all analytes compared. Analytical methods Laboratory certificates showed NATA endorsement for Appendix D NATA endorsed the analytical methods used. Chain of Custody Relevant CoCs were provided and the samples were Appendix E (CoC) noted to have been analysed within the appropriate documentation & holding times. holding times Adequacy of The QA/QC data from the assessments were QA/QC generally considered to be satisfactory. Transcription of No issues were noted that would materially impact Data by Assessor upon the conclusions of the report.

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Objective Comments Report Assessment Although gaps were noted, the data was considered Conclusions adequate to provide a preliminary assessment of groundwater impacts at the site. Kilpatrick & Associates, May 2002(11) Intra-laboratory One intra-laboratory duplicate was taken for four Attachment VI duplicates primary samples. Table 8 No inter-laboratory duplicates were collected during Inter-laboratory the sampling. duplicates No Rinsate blanks were collected during sampling. Rinsate blanks Trip blanks Trip blanks were not collected during the sampling Background A background sample was obtained from off-site bore samples MW13. Relative percent RPD for the intra-laboratory blind duplicate was Attachment VI difference (RPD) acceptable for all analytes compared. Table 8 Analytical methods Laboratory certificates showed NATA endorsement for Attachment VII NATA endorsed the analytical methods used. Chain of Custody Relevant CoCs were provided and the samples were Faxed copies with (CoC) noted to have been analysed within the appropriate the Activity documentation & holding times. Description for QA holding times Adequacy of The QA/QC data from the assessments were QA/QC generally considered to be satisfactory. Transcription of No issues were noted that would materially impact Data by Assessor upon the conclusions of the report. Assessment An absence of quality control procedures was noted, Conclusions however the data was considered adequate to provide an indication of groundwater impacts at the site. Kilpatrick & Associates, March 2003 and Kilpatrick & Associates, December 2003 (amendments) (12,13) Intra-laboratory Only cyanide was analysed for the sample taken and Laboratory duplicates the results were below the laboratory quantitation Reports limits. The frequency of intra-laboratory duplicates was unacceptable due to only one analyte having been tested. Inter-laboratory duplicates Only cyanide was analysed for the sample taken and the results were below the laboratory quantitation limits. The frequency of inter-laboratory duplicates was unacceptable due to only one analyte having Rinsate blanks been tested. Only cyanide was analysed for the rinsate sample and the results were below the laboratory quantitation limits. The frequency of rinsate blanks was unacceptable due to only one analyte having been tested. Trip blanks Trip blanks were not collected during the sampling Background A background sample was obtained from off-site bore Laboratory samples MW13. Reports Relative percent RPD for the intra-and inter-laboratory duplicates was Laboratory difference (RPD) based on the single analyte analysed (cyanide), which Reports reported concentrations below the quantitation limit.

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Objective Comments Report Analytical methods Laboratory certificates showed NATA endorsement for Laboratory NATA endorsed the analytical methods used. Reports Chain of Custody Relevant CoCs were provided and the samples were Laboratory (CoC) noted to have been analysed within the appropriate Reports documentation & holding times. holding times Adequacy of The QA/QC data from the assessments were QA/QC generally considered to be satisfactory, however duplicate samples analysed only one of the chemicals of concern identified at the site. This was considered marginally acceptable. Transcription of No errors were identified that would materially impact Report Tables 11, Data by Assessor upon the conclusions of the report. 12. Assessment Limited quality control procedures were implemented Conclusions for the assessment. However the data was considered adequate to provide an indication of groundwater impacts at the site. Kilpatrick & Associates, July 2004(14) Intra-laboratory Two intra-laboratory duplicates were taken for 26 Kilpatrick & duplicates samples. Associates, August 2004 - Inter-laboratory Two inter-laboratory duplicates were taken for 26 Table 1 duplicates samples. Rinsate blanks Two rinsate blanks were obtained during ten days of site works. The frequency of rinsate blanks was acceptable based on the use of dedicated micro-purge equipment. Trip blanks The frequency of trip blanks was not acceptable. Two Kilpatrick & trip blanks were obtained during ten days of site Associates, works. August 2004 - Table 1 Background A background sample was obtained from off-site bore samples MW13. Relative percent RPD results for the intra-and inter-laboratory Kilpatrick & difference (RPD) duplicates were acceptable except for one analyte Associates, which had an RPD of 185%. This was considered to August 2004 - be due to the low concentrations of analytes. Table 1 Analytical methods Laboratory certificates showed NATA endorsement for NATA endorsed the analytical methods used. Chain of Custody Relevant CoCs were provided and the samples were Kilpatrick & (CoC) noted to have been analysed within the appropriate Associates, documentation & holding times. August 2004 - holding times Laboratory Reports Adequacy of The QA/QC data from the assessments were QA/QC generally considered to be satisfactory. Transcription of No errors were identified that would materially impact Data by Assessor upon the conclusions of the report. Assessment Limited quality control procedures were implemented Conclusions for the assessment. However the data was considered adequate to provide an indication of groundwater impacts at the site.

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Objective Comments Report Kilpatrick & Associates, August 2004 (reports QA for March 2003, December 2003 and July 2004) (15) Intra-laboratory Intra-laboratory duplicates were analysed at 1 per 20 duplicates samples during each of the sampling periods March 2003, December 2003 and July 2004.

One inter-laboratory duplicate was lost in transit Inter-laboratory (December 2003). No inter-laboratory duplicate was duplicates analysed during this sampling period (December 2003). Sufficient inter-laboratory duplicates were analysed for the March 2003 and July 2004 sampling periods. Rinsate blanks One rinsate blank was collected for each day of sampling for the March 2003, December 2004 and July 2004 sampling periods. Rinse blanks analysed reported concentrations of analytes below the practical quantitation limits. Trip blanks One trip blank was collected for the December 2003 sampling period. No other trip blanks were taken. Background No background samples were taken during the samples sampling periods March 2003, December 2003 and July 2004. Relative percent One intra-laboratory groundwater sample reported an difference (RPD) RPD outside of the recommended 30-50% range at 70% RPDs. Two inter-laboratory duplicates fell outside of the recommended 30-50% range at 148% and 185%. Analytical methods All methods were NATA endorsed. NATA endorsed Chain of Custody Chain of custody protocols were observed during the (CoC) sampling periods March 2003, December 2003 and documentation & July 2004. Appropriate sample holding times were holding times observed. Adequacy of The QA QC was considered adequate for the QA/QC purposes of the assessment. Transcription of Data transcription was acceptable. Data by Assessor Assessment The data quality and quality control procedures were Conclusions considered adequate for the purposes of the Audit. Kilpatrick & Associates, September 2005(16) Intra-laboratory One groundwater intra-laboratory duplicate was Table 10 duplicates analysed out of a total of ten primary samples. Inter-laboratory One groundwater inter-laboratory duplicate was duplicate analysed out of a total of ten primary samples. Rinsate blanks One rinsate blank was collected for each day of sampling. Trip blanks No trip blanks were collected during groundwater Report body sampling. Background An upgradient groundwater sample was collected at Report body samples MW13. Relative percent All RPDs were within the acceptable range. Table 10 difference (RPD)

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Objective Comments Report Analytical methods All analytical methods were NATA accredited. Laboratory NATA endorsed Reports Chain of Custody Chain of custody documentation and appropriate Laboratory (CoC) sample holding times were upheld. Reports documentation & holding times Adequacy of The QA QC program was considered adequate. QA/QC Transcription of Some errors in data transcription were noted with Tables 7 and 8, Data by Assessor respect to detection limits. These errors did not impact Laboratory on the final analysis of the data. Reports Assessment Although some deficiencies were noted in the QA QC Conclusions program, it was considered adequate for the purposes of the audit. Kilpatrick & Associates, November 2005(17) Intra-laboratory One groundwater intra-laboratory duplicate was Table 6, duplicates analysed out of a total of ten primary samples. Laboratory Reports Inter-laboratory One groundwater inter-laboratory duplicate was duplicates analysed out of a total of ten primary samples. Rinsate blanks A rinsate blank was collected on five of the six days of sampling. One rinsate blank reported cyanide above the practical quantitation limit (and adopted investigation level) of 0.005 at 0.007mg/L. Trip blanks No trip blanks were collected for groundwater Table 6, analysis. Laboratory Reports Background An upgradient groundwater sample was collected at Report body samples MW13. Relative percent All RPDs were within the acceptable range. Table 6 difference (RPD) Analytical methods All analytical methods were NATA accredited. Laboratory NATA endorsed Reports Chain of Custody Chain of custody documentation and appropriate Laboratory (CoC) sample holding times were upheld. Reports documentation & holding times Adequacy of The QA QC program was considered adequate. QA/QC Transcription of No errors in data transcription were noted. Table 3and 4, Data by Assessor Laboratory Reports Assessment Although minor deficiencies were noted in the QA QC Conclusions program, it was considered adequate for the purposes of the audit. Kilpatrick & Associates, March 2006(18) Intra-laboratory One groundwater intra-laboratory duplicate was Table 6, Report duplicates analysed out of a total of nine primary samples. Body Inter-laboratory One groundwater inter-laboratory duplicate was duplicates analysed out of a total of nine primary samples. Rinsate blanks A rinsate blank was collected on each day of sampling. All rinsate blanks reported concentrations

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Objective Comments Report below the practical quantitation limits. Trip blanks No trip blanks were collected for groundwater Table 6, Report analysis. Body Background An upgradient groundwater sample was collected at Report Body samples MW13. Relative percent All RPDs were within the acceptable range, except for Table 6 difference (RPD) one marginal exceedance at 52%. Analytical methods All analytical methods were NATA accredited. Analytical Reports NATA endorsed Chain of Custody Chain of custody documentation and appropriate Analytical Reports (CoC) sample holding times were upheld. documentation & holding times Adequacy of The QA QC program was considered adequate. QA/QC Transcription of No errors in data transcription were noted. Tables 3 and 4, Data by Assessor Laboratory Reports Assessment Although some deficiencies were noted in the QA QC Conclusions program, it was considered adequate for the purposes of the audit. Kilpatrick & Associates, July 2007(21) Intra-laboratory One groundwater intra-laboratory duplicate was Table 6, Report duplicates analysed out of a total of nine primary samples. Body Monocyclic aromatic hydrocarbons (MAH) and Inter-laboratory cyanide were the analytes analysed. duplicates One groundwater inter-laboratory duplicate was Rinsate blanks analysed out of a total of nine primary samples. MAH and cyanide were the analytes analysed. A rinsate blank was collected on each day of sampling. All rinsate blanks reported concentrations below the practical quantitation limits. MAH and cyanide were the analytes analysed. Trip blanks One trip blank was collected for groundwater analysis Table 6, Report and reported concentrations below the practical Body quantitation limits. Background An upgradient groundwater sample was collected at Report Body samples MW13. Relative percent All RPDs were within the acceptable range. Table 6 difference (RPD) Analytical methods All analytical methods were NATA accredited. Analytical Reports NATA endorsed Chain of Custody Chain of custody documentation and appropriate Analytical Reports (CoC) sample holding times were upheld. documentation & holding times Adequacy of The QA QC program was considered adequate. QA/QC Transcription of No errors in data transcription were noted. Tables 3 and 4, Data by Assessor Laboratory Reports

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Objective Comments Report Assessment Limited analytes were included in the quality control Conclusions program. The analytes selected were the primary analytes of concern (cyanide and MAH) at the site and therefore it was considered sufficient. The QA QC program was considered adequate for the purposes of the audit. Bureau Veritas , June 2008(22) Intra-laboratory Two intra-laboratory duplicates were analysed during duplicates each round of sampling out of a total of 26 primary samples. Only MAH were analysed from the suite of analytes.

Inter-laboratory Two inter-laboratory duplicates were analysed during duplicates each round of sampling out of a total of 26 primary samples. Only MAH were analysed from the suite of analytes. Rinsate blanks One rinsate blank was analysed for each day of sampling (with the exception of one day during round 11). Low concentrations of benzene, ethylbenzene and toluene were reported in the rinsate blanks. The concentrations reported were not expected to impact on the analytical results. Trip blanks Trip blanks were collected for each day of sampling and reported low concentrations of benzene, ethylbenzene and toluene. The concentrations reported were not expected to impact on the analytical results. Background An up-hydraulic gradient sample was taken at MW13 samples during each sampling round. Relative percent The RPDs were above 50% for some samples, difference (RPD) however this was due to differing laboratory detection limits between the primary and secondary laboratories and was not considered to impact on the results. Analytical methods All methods were NATA endorsed. NATA endorsed Chain of Custody Chain of custody documentation and appropriate (CoC) sample holding times were upheld. documentation & holding times Adequacy of The QA QC program was considered adequate. QA/QC Transcription of Some minor errors in data transcription were noted. Data by Assessor The revised data tables are attached as Appendix B. Assessment Minor deficiencies were noted in the QA QC program, Conclusions however it was considered adequate for the purposes of the audit. OVERALL AUDIT SUMMARY OF QA/QC – The quality control data in the various assessment reports varied. Assessments performed up to December 2003 had insufficient quality control data. From July 2004, the QA/QC procedures were generally considered acceptable for the purposes of the audit with some minor deficiencies that were not expected to affect the conclusions of this audit.

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Based on the above, the Auditor considers the available groundwater data to be of suitable quality and completeness to support the enclosed Statement of Environmental Audit.

5.5 Surface Water Investigations

Details of the quality of surface water investigations undertaken are detailed in Table 5-4 below.

Table 5-4: Quality of surface water investigation works

Objective Comments Reports Point sources Surface samples were obtained at Upstream, Kilpatrick & targeted Midstream and Downstream points along Gardiners Associates, Creek with respect to likely site groundwater outfall. September 2005(16); Sampling method Surface water sampling method was by grab sample into a laboratory supplied sample container. The Kilpatrick & sample depth was reported at between 500 and Associates, 700mm below water surface. November 2005(17); Contaminants The analytes tested for were metals, total dissolved analysed solids, TPHs, PAHs, phenols, cresols, thiocyanate, Kilpatrick & consistent with BTEX and cyanide (total and free), and were Associates, March (18) operations, history considered to adequately address potential issues 2006 ; or EPA screen associated with the previous site use. Kilpatrick & Background The background sample consisted of the “Upstream” Associates, July (21) samples location. 2007 ; Bureau Veritas, 2008(22) QA/QC sampling Blind Duplicates: (As above) Report frequency and RPD tables, results Adequate blind duplicates were submitted for the laboratory reports surface water monitoring events recorded RPDs were generally satisfactory. Split Duplicates: Adequate split duplicates were submitted for the surface water sampling events recorded. RPDs were generally satisfactory. Rinsate Blanks: Rinsate blanks were not collected during all rounds of surface water sampling. Rinsate blanks were taken during Rounds 13, 15, 16, 17 and reported concentrations of analytes below the quantitation limits. Trip Blanks: Trip blanks were collected and reported analyte concentrations below the detection limits. CoC Chain of custody documentation and appropriate (As above) documentation and sample holding times were upheld. holding times

Laboratories and All analytical methods were NATA accredited. tests used NATA accredited

Adequacy of The QA QC program was considered adequate. QA/QC (As above)

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Objective Comments Reports Transcription of No significant transcription issues were noted. data Assessment criteria The assessment criteria were considered acceptable in view of the identified beneficial uses of surface water. Assessment The conclusions of the assessment reports are conclusions considered acceptable.

Based on the above, the Auditor considers the available groundwater data to be of suitable quality and completeness to support the enclosed Statement of Environmental Audit.

5.6 Auditor observations of field protocols

From the auditor and his representative’s observations of the field works, the soil, groundwater and surface water sampling procedures employed were noted to be consistent with the methodologies outlined in the respective reports(6-22) and generally adequate and consistent with practises recommended in the EPA guidelines(24,35). Minor discrepancies observed were considered unlikely to affect the outcomes of the audit.

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6. Discussion

This section outlines the Auditor’s opinion on the impact to the beneficial uses of the land and groundwater caused by residual soil and groundwater impacts at the site. This discussion is based on the assumption that the underground car park will be demolished and filled. Additional assessment of exposure to hydrocarbon vapours by users of the car park will be required in the event that this structure is retained.

6.1 Beneficial uses of land

A summary of potential impacts to beneficial uses of the land is provided in Table 6-1 below. Information on the condition of soil on Lot 1 (PS406054P) in the northwest corner of the site and other underground service easements along the Gardiners Creek margin of the site is limited (Figure 2). As such, there is some uncertainty on the potential for impacts to beneficial uses in this area and any activities in these areas involving soil disturbance should be appropriately managed.

Table 6-1: Assessment of impacts to beneficial uses of land

Protected beneficial On site use Service easements and off site use uses Maintenance of Unlikely Potential ecosystems Potential risk to some flora and The origin of fill place in easements (highly modified) fauna, though considered unlikely along the Gardiners Creek margin of given the highly modified the site is uncertain. Potential risk to ecosystem and the nature of some flora and fauna, though development. Some topsoil may considered unlikely given the highly be required to establish plantings modified ecosystem. in landscaped areas. Human Health Unlikely Potential Direct contact with soil by site Low although unquantified risk. The occupiers under proposed presence of underground services commercial development precludes any development beyond scenario is unlikely. open space/landscaping. Low but manageable risk to Intrusive soil works should be construction workers involved in undertaken under a management plan removal of residual soil impacts that outlines appropriate controls for during site development. exposure to potential soil impacts and disposal of impacted soil. Low but manageable risk to maintenance workers involved in trenching or excavation of soil in vicinity of residual soil impacts and the below ground car park. Buildings and Unlikely Unlikely structures Soils on the site are not On the assumption that off-site soil considered to be corrosive. impacts (if present) are similar to those encountered on site.

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Protected beneficial On site use Service easements and off site use uses Aesthetics Potential Potential Brick or concrete rubble may be Unknown potential for rubble or other present in shallow soils and fill deleterious material, or odours in soils material and will require and fill containing residual organic management during site impacts. development. Potential for odours in soils and fill containing residual organic impacts.

6.2 Beneficial uses of groundwater

An assessment of potential impacts to groundwater beneficial uses is provided in Table 6.2 based on the classification of groundwater as Segment A2.

Groundwater at the site was found to be impacted by cyanide, BTEX, TPH, PAH, phenols, cresols. With the exception of lead, the presence of various metals in groundwater is considered to represent regional impacts, being typical of an established built environment, or background (natural) concentrations.

No surface water bodies are currently present on-site although development plans indicate the presence of an ornamental lake. Gardiners Creek follows the line of the western and southern boundary approximately 25 metres from the site. Protection of ecosystems has been applied based on groundwater interaction with the creek. Beneficial uses of surface water that need to be protected are considered to be those associated with freshwater ecosystems of Urban Waterways, as specified in the SEPP WoV(36) including Schedule F7 Waters of the Yarra Catchment(29).

Table 6-2: Assessment of impacts to relevant groundwater beneficial uses

Protected On site use Off site use beneficial uses Maintenance Potential Existing of There are currently no receiving Gardiners Creek is the receiving surface ecosystems surface water bodies on the site. water body located immediately to the west/southwest. Groundwater quality below the site would not be suitable to fill or maintain ornamental lakes without treatment and testing. Potable water Unlikely Unlikely - acceptable Inconsistent with current site and Inconsistent with current site and surrounding land use. A fully surrounding land use. A fully reticulated reticulated water supply is available water supply is available and background and background quality may restrict quality may restrict use. use. Mineral water Unlikely Unlikely The site is not located within a There is no designated mineral springs designated mineral springs area. area in the locality.

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Protected On site use Off site use beneficial uses Agriculture, Potential Potential parks and Site development plans include Possible to use groundwater for watering gardens some gardens. Background quality of parks and gardens. Background quality may restrict use. If sufficiently may restrict use. treated, groundwater re-use is an option for the site. Stock Unlikely Unlikely watering Inconsistent with the proposed Located in an urban area, therefore commercial development. unlikely. Industrial use Unlikely Unlikely The site is proposed as a Surrounding land use is primarily commercial development and a residential and light commercial. fully reticulated water supply is Background quality may restrict use. available, therefore this use is unlikely. Primary Potential Potential contact Although unlikely, the use of The use of groundwater to fill a swimming recreation groundwater to fill a swimming pool pool is feasible. However due to the (bathing, or ornamental lake is feasible. presence of a reticulated water supply this swimming) use is unlikely to be realised. Recreational activities in and around Gardiners Creek adjacent to the site would be limited by the steep banks and dense vegetation, although better access and more pleasant amenity is available downstream of the site. Buildings Unlikely Unlikely and The observed groundwater impacts The observed groundwater impacts are not Structures are not considered likely to cause considered likely to cause corrosive corrosive conditions. conditions.

In summary, the beneficial uses of groundwater that are relevant to the site and that may be precluded by the observed impacts are:

Maintenance of ecosystems - due to the close proximity of Gardiners Creek. Primary contact recreation – filling of swimming pools and ornamental lakes, recreational activities in and around Gardiners Creek. Agriculture parks and gardens – irrigation of parks and gardens both on and off-site.

6.3 Groundwater quality restricted use zone

Due to the potential preclusion of some beneficial uses of groundwater at the site and down gradient of the site, the Auditor considers that a Groundwater Quality Restricted Use Zone (GQRUZ) is an appropriate mechanism to manage residual risks associated with groundwater. The extent of the GQRUZ, as agreed with the EPA, is illustrated in Figure 8.

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7. Conclusions

The following conclusions are based on information supplied within the assessment reports(6-22) and should be read in conjunction with the document “Information Supplied to Assist in the Understanding of an Environmental Audit Report (Contaminated Land)” included in Appendix E.

Soil remediation work has largely removed the sources of contamination from the site. Several locations could not be remediated due to the presence of infrastructure or mature trees, which prevented further excavation. Refer to Figure 5 for the location of residual soil impacts. Excavations were validated to HIL-F criteria. Further remediation of soil is not considered necessary, based on the limited extent of the impacts and the requirement for surface covering over these areas. These areas are not considered to be significant on- going sources of groundwater impact. Any residual impacts not identified during site investigation works will be prevented from impacting the creek with the implementation of the Groundwater Quality Management Plan(33) and associated hydraulic boundary control system. The requirement for surface covering at the site will also address the poor aesthetic impacts within some fill material.

The following groundwater protected beneficial uses (on and off-site) may be precluded due to the reported cyanide, BTEX, TPH, PAH, phenols, metals, and cresols concentrations in the groundwater beneath the site:

maintenance of ecosystems potable water - acceptable stock watering industrial agriculture, parks and gardens primary contact recreation The uses associated with industrial, potable water supply and stock watering are considered unlikely due to the urban nature of the locality and availability of a fully reticulated water supply.

The metals concentrations in groundwater, with the exception of lead, are considered to be typical of local groundwater quality and are not considered site contaminants based on concentrations of the metals up hydraulic gradient of the site.

There is a risk that residual groundwater impacts may impact maintenance of ecosystems at Gardiners Creek, immediately adjacent to the site. In order to control this risk a Groundwater Quality Management Plan(33) (GQMP) has been prepared for the continued monitoring of groundwater and where impacts to the creek exceed trigger levels the hydraulic boundary control system will be turned on. The location of groundwater monitoring and recovery wells associated with the GQMP are illustrated in Figure 7.

Based on the distribution of dissolved impacts, there is a possibility that further source of groundwater impacts are present in the vicinity of Gas Holder No. 1. These impacts present a potential health risk to users of the car park and a potential risk to sensitive receptors, particularly Gardiners Creek.

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The EPA has determined that the site has been cleaned up to the extent practicable and that the site is within a groundwater quality restricted use zone (GQRUZ) which includes the site, the land between the site and Gardiners Creek, and the land between the site and the northern boundary of Toorak Road. The extent of the GQRUZ is illustrated in Figure 8.

The Auditor has therefore considered that it is inappropriate to issue a Certificate of Environmental Audit for the site due to:

residual soil impacts (the presence of fill material and natural soil containing PAH and lead concentrations above the NEPM F criteria) cyanide, TPH, BTEX, phenols, cresols and lead concentrations in groundwater. aesthetic impacts associated with the fill material. The site in its current condition is considered suitable for the intended commercial development subject to the following:

A soil management plan is required for soil excavation works on Lot 1 (PS406054P) and other services easements along the Gardiners Creek margin of the site highlighted in Figure 4. The plan must address occupational health and safety and soil disposal issues in anticipation of hydrocarbon (PAHs) and metals concentrations above HIL-F criteria. Lot 1 (PS406054P) and other services easements along the Gardiners Creek margin of the site highlighted in Figure 5 should be covered with hard pavements or a sufficient thickness of clean fill so as to ensure that underlying soil or fill is not disturbed, eroded or otherwise accessible during normal functions associated with commercial or public open space related activities. Groundwater must not be extracted for any use other than clean-up, hydraulic containment or monitoring. The Groundwater Quality Management Plan(33) prepared for the site and approved by EPA is to be implemented. The Groundwater Quality Management Plan details the following: The design of a contingency system for hydraulic containment. Installation of the contingency system including all fixed infrastructure. The process for demonstrating the capability of the containment system to effectively control contaminant migration and impact on Gardiners Creek. A monitoring program including groundwater and surface water, monitored wells, analytical program and methodology, monitoring frequency, program duration, review procedure, reporting requirements and roles and responsibilities. Trigger conditions for implementation of the contingency system in accordance with EPA Publication 840 and a detailed description of subsequent actions in case the trigger is exceeded. By September 2009, complete an environmental audit under Section 53V of the Act to re-assess the risk of harm to Gardiners Creek caused be the discharge of polluted groundwater from the site. Maintenance of the ability to operate the contingency system until such time as otherwise instructed by EPA in writing.

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The underground car park (Gas Holder No. 1) must be backfilled or alternatively a further risk assessment must be carried out prior to its use if the structure is not backfilled. The risk assessment must be reviewed by an EPA appointed environmental auditor and recommendations made by the auditor must be implemented. Appropriate advice should be sought to assist in the appropriate management and/or disposal of fill or other impacted material at the site. The above management conditions and related information have been reflected in the conditions on the attached Statement of Environmental Audit in this report.

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8. References

1. Environment Protection Act 1970 Victoria. Act No. 8056/1970. (EPA 1970)

2. Environmental Auditor Guidelines - Provision of environmental audit reports, certificates and statements, EPA Victoria, Publication 1147, September 2007 3. Environmental Auditing of Contaminated Land, EPA Victoria, Publication 860.1, August 2007. 4. Environmental Auditor (Contaminated Land) – Guidelines for Issue of Certificates and Statements of Environmental Audit, EPA Victoria, Publication 759.1, September 2007. 5. Environmental Auditor Guidelines for Appointment and Conduct, EPA Victoria, Publication 865.6, August 2007. 6. CMPS&F, Department of Treasury and Finance, Site Investigation, Tooronga Depot, Kaikoura Avenue, Tooronga, Victoria. October 1997. 7. GSB Land Remediation Division, Multinet, Soil Contamination Assessment of Proposed Parking Areas, No. 16 Kaikoura Avenue, Tooronga. January 1998. 8. Egis Consulting, United Energy, Tooronga Office Site Victoria, Environmental Site Assessment Report. September 1999. 9. Egis Consulting, Australand Holdings 742 Toorak Road, Hawthorn East Supplementary Environmental Site Assessment Report. February 2001. 10. VEMCO Environmental Services, Site History Appraisal & Assessment Summary, 742 Toorak Road, Hawthorn East. October 2001. 11. Kilpatrick & Associates Pty Ltd, Environmental Status Report - 742 Toorak Road, Hawthorn East. May 2002. 12. Kilpatrick & Associates Pty Ltd, Environmental Site Assessment, 742 Toorak Road, Hawthorn East (Arcadia Grove). March 2003. 13. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). December 2003. 14. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). July 2004. 15. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East - Groundwater Status Report. August 2004. 16. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). September 2005. 17. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). November 2005. 18. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). March 2006. 19. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). June 2006.

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20. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). October 2006. 21. Kilpatrick & Associates Pty Ltd, RE: 742 Toorak Road, Hawthorn East (letter report). July 2007. 22. Bureau Veritas HSE Pty Ltd, Environmental Audit, Summary of Works August 2007 – May 2008, 742 Toorak Road, Hawthorn East, VIC. June 2008. 23. State Environment Protection Policy (Prevention and Management of Contamination of Land), Environment Protection Act 1970, Victoria, June 2002. 24. National Environmental Protection Measure (Assessment of Site Contamination), National Environmental Protection Council, December 1999. 25. NSW EPA Service Station Guideline Levels for Sensitive land Uses (1994). Assessment, Classification & Management of Liquid & Non-liquid Wastes Department of Environment & Conservation (NSW). 26. State Environment Protection Policy (Groundwaters of Victoria), Environment Protection Act 1970, Victoria, December 1997. 27. NHMRC and ARMCANZ Australian Drinking Water Guidelines, 1996. 28. Australian Water Quality Guidelines for Fresh and Marine Waters, ANZECC 1992. 29. State Environment Protection Policy (Waters of Victoria), Insertion of Schedule F7 Waters of the Yarra Catchment, Environment Protection Act 1970, Victorian Government Gazette No. S 89, 22 June 1999. 30. Circular on Target Values and Intervention Values for Soil Remediation, Ministry of Housing, Spatial Planning and Environment, The Netherlands, February 2000. 31. Australian and New Zealand Environment & Conservation Council, 2000. Australian Water Quality Guidelines for Fresh and Marine Waters.2000.

32. National Health and Medical Research Council and National Resource Management Ministerial Council, Australian Drinking Water Guidelines, Australian Government, 2004. 33. Bureau Veritas, 2009. Groundwater Quality Management Plan, 742 Toorak Road, Hawthorn East. Rev 5 February 2009. 34. EPA Publication 448.1 (May, 2004) Classification of Wastes.

35. Groundwater Sampling Guidelines, Environment Protection Authority, Victoria, EPA Publication 669, April 2000. 36. State Environment Protection Policy (Waters of Victoria), Environment Protection Act 1970, Victorian Government Gazette No. S 107, 5 June 2003. 37. Bureau Veritas, 2008. Groundwater Quality Management Plan Reference Document, 742 Toorak Road, Hawthorn East. July 2008. 38. Australian Standard AS4482.1 - 2005, Guide to the Sampling and Investigation of Potentially Contaminated Soil Part 1: Non-volatile and Semi-volatile Compounds.

39. Australian Standard AS4482.2 - 1999, Guide to the Sampling and Investigation of Potentially Contaminated Soil Part 2: Volatile substances. 40. Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites, ANZECC / NHMRC, January 1992.

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41. US EPA, Region 9 Superfund Preliminary Remediation Goals. 2004.

42. Australian Standard AS2159 – 1995, Piling – Design and Installation.

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Appendix A

Figures

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Appendix B

Tabulated Laboratory Results (Groundwater and Surface Water) from Bureau Veritas June 2008 Report

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Appendix C

Certificate of Title

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Appendix D

Correspondence

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Appendix E

CUTEP Report

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Appendix F

Information Supplied to Assist in the Understanding of an Environment Audit Report (Contaminated Land)

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Appendix G

Assessor Reports

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Appendix H

Groundwater Quality Management Plan & Reference Document

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